Wesley Sherwood - Page 6

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          stated that he owed $12,251, including $188.32 of interest, and             
          asked him to pay that amount immediately.  On January 10, 2001,             
          Kotmair responded to the notice of intent to levy by sending 5              
          pages of frivolous arguments to the Director of the Ogden Service           
          Center.                                                                     
          F.   Petitioner’s Tax Returns for 1999, 2000, and 2001                      
               On March 5, 2002, petitioner filed returns on which he                 
          reported tax liabilities of $9,050 for 1999 and $11,211 for 2000.           
          Petitioner had no Federal income tax withheld and paid no Federal           
          income tax for 1999 or 2000.                                                
               Petitioner filed a 2001 return before April 8, 2002.  In it,           
          he reported that he owed $9,787 in tax, had no Federal income tax           
          withheld, and paid no Federal income tax for 2001.  Respondent              
          assessed petitioner’s Federal income tax for 2001 in the amount             
          of $10,1862 on April 8, 2002.  On May 13, 2002, respondent issued           
          a notice and demand for payment of petitioner’s Federal income              
          tax for 2001.                                                               
          G.   Petitioner’s 2002 Tax Year                                             
               On June 9, 2003, respondent assessed against petitioner a              
          penalty in the amount of $500 under section 6682 for submitting             





               2  Respondent assessed the tax that petitioner reported and            
          did not pay and an additional amount not explained in the record.           





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