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incurred in 1994, 1995, and 1996. Unless otherwise indicated,
all section references are to the Internal Revenue Code, as
amended.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Raleigh, North Carolina, at the time that
the petition was filed.
On May 10, 2002, respondent sent to petitioner a
Letter 1058 (Final Notice - Notice of Intent to Levy and Notice
of Your Right to a Hearing) under section 6330 with respect to
petitioner’s Federal income taxes for 1993. Attached to the
Letter 1058 was an account summary showing that petitioner’s
liability for 1993 consisted of an assessed balance of $6,499.97
plus statutory additions to tax (penalties and interest) of
$3,275.73, for a total of $9,775.70. Petitioner responded to the
Letter 1058 by submitting a timely Request for Collection Due
Process Hearing (Form 12153) dated May 29, 2002. A telephonic
hearing was held in which petitioner contended that he incurred
Schedule C, Profit or Loss From Business, losses in later periods
that he thought should offset the income from 1993 reported on
the return as filed.
On June 17, 2003, the Office of Appeals mailed to petitioner
a Notice of Determination Concerning Collection Action(s) Under
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Last modified: May 25, 2011