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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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