Brian and Tina Nicklaus - Page 4

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          not shown any irregularity in respondent’s assessment procedures.           
          Id. at 120-122.                                                             
          B.   Respondent’s Notice of Levy for Petitioner’s Tax Years 1993-           
               2000 and Tina Nicklaus’s Tax Years 1993-94                             
               Respondent prepared substitutes for petitioner’s returns for           
          tax years 1997-99 on February 1, 2001, and for 2000 on July 11,             
          2002.  Respondent issued notices of deficiency to petitioner for            
          1997-2000 on dates not stated in the record.  Petitioner did not            
          file a petition in this Court for those years.  Respondent                  
          assessed tax, additions to tax, and interest for petitioner’s tax           
          years 1997-99 on July 14, 2003, and for his tax year 2000 on                
          September 8, 2003.                                                          
               On September 9, 2004, respondent sent a Final Notice -                 
          Notice of Intent to Levy and Notice of Your Right to a Hearing to           
          Tina Nicklaus for income taxes for 1993 and 1994 and to                     
          petitioner for 1993-2000.  Petitioners filed separate requests              
          for a hearing under section 6330(b).                                        
               Appeals Officer Jean Duncan (Duncan) was assigned to                   
          petitioners’ case.  Duncan gave petitioners Forms 4340 for 1993-            
          2000 before the hearing under section 6330(b).  As part of their            
          section 6330(b) hearing, petitioners gave Duncan seven documents            
          including petitioner’s description of respondent’s actions with             
          respect to petitioners’ 1993-2000 tax years and copies of various           
          transcripts.                                                                







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