Juanita and Emmanuel Kendricks - Page 2

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               determining to proceed by levy to collect the unpaid                   
               assessments of tax.                                                    

               Neal Weinberg, for petitioners.                                        
               Brianna Basaraba Taylor, for respondent.                               


               HALPERN, Judge:  This case is before the Court to review               
          determinations made by respondent’s Appeals Office (Appeals) that           
          respondent may proceed to collect by levy amounts assessed but              
          unpaid with respect to petitioner Juanita Kendricks’s 1982                  
          through 1984 taxable (calendar) years and petitioners Juanita and           
          Emmanuel Kendricks’ 1985 taxable (calendar) year (collectively,             
          the unpaid assessments).1  We review the determinations pursuant            
          to section 6330(d)(1).2  Petitioners (individually, Mr. or Mrs.             
          Kendricks) assign error to the determinations on the grounds that           
          (1) they did not receive notices of deficiency for the years in             
          issue in time to file a petition in the Tax Court, and,                     
          therefore, Appeals should not have denied them the opportunity to           

               1  For 1982 through 1984, Mrs. Kendricks made separate                 
          returns of income; for 1985 petitioners made a joint return of              
          income.  Mr. Kendricks’s 1982 through 1984 taxable years are not            
          before us.                                                                  
               2  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code of 1986, as amended, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            

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