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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
sustained.
An attachment to the notice of determination stated in pertinent
part:
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-
tained.
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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