Meredyth E. Kilgore - Page 4

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               Respondent prepared a substitute tax return1 for petitioner            
          based on the information reported to respondent by third parties.           
          The substitute tax return reported adjusted gross income of                 
          $122,429, which included $853 in wages, $116,188 from the sale of           
          stocks and bonds, $5,129 in dividends, and $259 in interest.                
               On July 5, 2000, respondent issued a statutory notice of               
          deficiency for 1996 to petitioner’s last known address.                     
          Respondent determined a deficiency of $31,089, a section                    
          6651(a)(1) failure-to-file penalty of $6,991.42, a section                  
          6651(a)(2) failure-to-pay penalty of $7,768.25, a section 6654(a)           
          estimated tax penalty of $1,653.79.  Petitioner received the                
          notice of deficiency but did not petition the Tax Court for                 
          redetermination, and respondent assessed a total tax liability of           
          $60,126.33.2                                                                
               Respondent subsequently issued a Final Notice Notice of                
          Intent to Levy and Notice of Your Right to a Hearing.  In the               
          notice, respondent informed petitioner of respondent’s intent to            
          levy and of petitioner’s right to a hearing before respondent’s             
          Appeals Office pursuant to section 6330.  In response, petitioner           

               1We are not called on to decide whether the return prepared            
          by respondent met the requirements of a substitute return under             
          sec. 6020(b).  See Swanson v. Commissioner, 121 T.C. 111, 112 n.1           
          (2003).                                                                     
               2The assessed tax liability included a deficiency of                   
          $31,089, a sec. 6651(a)(1) penalty of $6,991.42, a sec.                     
          6651(a)(2) penalty of $6,836.06, a sec. 6654(a) penalty of                  
          $1,653.79, and $13,572.06 of interest.                                      





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