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established his liability for income taxes or required him to
file a return.
Respondent issued to petitioner a statutory notice of
deficiency for 1999 on January 18, 2002, and for 2000 on February
1, 2002. The deficiencies determined for 1999 and 2000 were
$13,896 and $19,833, respectively. Respondent also determined
accuracy-related penalties under section 6662(a) in the
respective amounts of $2,259 and $3,967. Petitioner at no time
petitioned this Court for redetermination of the deficiency and
penalty reflected in either notice. Respondent assessed tax,
penalty, and interest amounts due for 1999 and 2000 on
September 30, 2002, and sent notice(s) of balance due on that
date.
On February 11, 2003, respondent issued to petitioner a
Final Notice of Intent To Levy and Notice of Your Right To a
Hearing with respect to his unpaid liabilities for 1999 and
2000.2 Petitioner executed on February 24, 2003, and timely
submitted to respondent a Form 12153, Request for a Collection
Due Process Hearing, with multiple attachments setting forth his
disagreement with the proposed levy. He challenged the validity
2 The notice of intent to levy incorporated, in addition to
the income tax liabilities dealt with in the notice of
determination and at issue in this proceeding, civil penalties
under sec. 6702 for the filing of frivolous returns. This Court
lacks jurisdiction to review any issues related to those
penalties. Van Es v. Commissioner, 115 T.C. 324, 328-329 (2000).
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Last modified: May 25, 2011