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thereby decreasing the tax of $3,574 to $2,974.
On May 27, 2002, respondent assessed petitioner’s3 tax of
$2,974 for 2001, as well as interest as provided by law on the
amount of such unpaid tax.4 Respondent also summarily determined
that petitioner is liable for 2001 for the addition to tax under
section 6651(a)(2). (We shall refer to any unpaid assessed
amounts with respect to petitioner’s taxable year 2001, as well
as interest as provided by law accrued after May 27, 2002, as
petitioner’s unpaid liability for 2001.)
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid liability for 2001.
On June 26, 2003, respondent sent petitioner a final notice
of intent to levy and notice of your right to a hearing (notice
of intent to levy) with respect to petitioner’s unpaid liability
for 2001.
On July 21, 2003, in response to the notice of intent to
levy, petitioner filed Form 12153, Request for a Collection Due
Process Hearing, and requested a hearing with respondent’s
Appeals Office (Appeals Office).
3Ms. Lane is not a petitioner in the instant case. Herein-
after, we shall refer only to petitioner.
4Respondent credited tax withheld of $651.62 against peti-
tioner’s tax of $2,974 for 2001, thereby resulting in an unpaid
balance of tax of $2,322.38.
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Last modified: May 25, 2011