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MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent sent Notices of Determination
Concerning Collection Action(s) Under Section 63202 (Lien) and/or
6330 (Levy) to petitioners in which respondent determined that it
was appropriate to file liens with respect to petitioners’ unpaid
income taxes for 1996-2001 and that respondent may proceed with
proposed levies for the years 1999-2001.
We sustain respondent’s determinations to proceed with
collection of petitioners’ income tax liabilities for 1996-2001.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in Palm Coast, Florida, when the petitions
were filed. During the years in issue through the time of trial,
Homer W. Winans (petitioner) worked as a consultant to hospitals
and petitioner Nancy L. Winans (Mrs. Winans) worked as a nurse.
On a date not stated in the record, petitioner filed with his
employer a Form W-4, Employee Withholding Allowance Certificate,
in which he claimed that he was exempt from Federal income tax
withholding.
2 Unless otherwise provided, section references are to the
Internal Revenue Code as amended and in effect for the years in
issue.
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