Carey K. Parker II - Page 2

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          Background                                                                  
               At the time he filed the petition, petitioner resided in               
          Arlington, Texas.  Since at least 2000, petitioner has resided in           
          a private residence at 6411 Shorewood Drive, Arlington, Texas,              
          76016-2540117 (Shorewood address).                                          
               Petitioner failed to file income tax returns for 1994, 1995,           
          1996, and 1997.  On October 22, 1996, respondent assessed                   
          petitioner’s tax liability (including penalties and interest) for           
          1994, and on December 10, 2001, respondent assessed petitioner’s            
          tax liabilities (including penalties and interest) for 1995,                
          1996, and 1997.                                                             
               On September 2, 2003, respondent mailed petitioner a notice            
          of intent to levy and right to a section 6330 hearing for 1994,             
          1995, 1996, and 1997 at the Shorewood address (hearing notice).             
               After receiving no response to the hearing notice, on                  
          November 10, 2003, respondent mailed petitioner a Final Notice              
          Before Levy on Social Security Benefits.  As of November 10,                
          2003, petitioner owed taxes, penalties, and interest totaling               
          $42,272.55, $42,698.46, $40,945.03, and $33,522.46 for 1994,                
          1995, 1996, and 1997, respectively.                                         
               On December 7, 2003, petitioner mailed respondent a Form               
          12153, Request for a Collection Due Process Hearing (dated                  
          December 6, 2003) for 1994, 1995, 1996, and 1997 (hearing                   
          request).  Petitioner attached to the hearing request a 10-page             






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