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to his 1992, 1993, 1994, 1995, 1996, 1997, 1998, and 1999 taxable
years. Petitioner resided in New York, New York, when his
petition was filed.3
By letter dated July 26, 2004, respondent contacted
petitioner to schedule a meeting for August 16, 2004, to discuss
a stipulation of facts in this case. By letter dated August 10,
2004, petitioner informed respondent that he would be unable to
attend the scheduled meeting due to physical injuries received
during the previous month. Petitioner also stated that he had
begun gathering documentation for his case and needed respondent
to send him copies of his tax returns because petitioner’s copies
were “in storage”. By letter dated October 8, 2004, respondent
rescheduled the meeting for November 10, 2004. Petitioner
canceled the November 10, 2004, meeting by a telephone call to
respondent. Respondent rescheduled the meeting for December 3,
2004, and sent petitioner copies of his 1993, 1994, 1995, 1998,
2(...continued)
determination that respondent could proceed to collect by levy
petitioner’s unpaid income tax liabilities. One of petitioner’s
arguments in support of his claim that he does not owe the
liabilities is that he was an employee, and his employers should
have withheld income tax from his wages. Petitioner apparently
checked the employment status redetermination box because of this
argument. For reasons stated in this opinion, we do not
separately address petitioner’s argument.
3Petitioner alleges that the unpaid income tax liabilities
are the responsibility of his various employers throughout the
years in question. Petitioner also alleges that his 1992 and
1993 income tax liabilities were discharged in a ch. 7 bankruptcy
proceeding on Dec. 7, 1993.
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