Dawson Craig Lane - Page 6

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          (Form 1040X for 2001), that he had prepared for his taxable year            
          2001.  In Form 1040X for 2001, petitioner claimed child tax                 
          credits of $1,200 for his sons Caleb and Joshua.                            
               On August 10, 2004, the Appeals Office mailed to petitioner            
          a notice of determination.  The notice of determination stated in           
          pertinent part:                                                             
               Summary of Determination                                               
               The intent to levy, as proposed by the Internal Revenue                
               Service in its letter to you dated June 26, 2003, is                   
          An attachment to the notice of determination stated in pertinent            
               Summary and Recommendation                                             
                  *       *       *       *       *       *       *                   
               The issue is whether you have a valid challenge to the                 
               appropriateness of the notice of intent to levy by the                 
               Internal Revenue Service.  After conducting a hearing                  
               and taking into account your record of compliance, it                  
               is my recommendation that the intent to levy be sus-                   
               Brief History                                                          
               The liability for the above identified tax period                      
               [2001] results from under withholding and insufficient                 
               estimated tax payments.  In addition to the unpaid                     
               income tax liability, a portion of the balance due is                  
               composed of the statutory additions of the late payment                
               penalty and interest.  Your tax problems have continued                
               to accumulate because, it has been determined that you                 
               have not filed income tax returns for the years 1997,                  
               1998, 1999, 2000, and 2002.                                            
                  *       *       *       *       *       *       *                   

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Last modified: May 25, 2011