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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.
OPINION
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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Last modified: May 25, 2011