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tioner’s total tax was $5,750, which respondent assessed on
February 15, 1999. With respect to petitioner’s taxable year
1994, respondent concluded that petitioner’s total tax was
$4,744, which respondent assessed on March 29, 1999. With
respect to petitioner’s taxable year 1995, respondent concluded
that petitioner’s total tax was $5,764, which respondent assessed
on December 14, 1998. With respect to petitioner’s taxable year
1996, respondent concluded that petitioner’s total tax was
$2,471, which respondent assessed on June 2, 1997.
On November 29, 2000, respondent sent petitioner a final
notice--notice of intent to levy and notice of your right to a
hearing (notice of intent to levy) with respect to the respective
amounts of tax that respondent concluded petitioner owed for her
taxable years 1993 through 1996.
On December 26, 2000, respondent received Form 12153,
Request for a Collection Due Process Hearing, from petitioner.
Respondent’s Appeals officer (Appeals officer) held three
face-to-face hearings with petitioner with respect to the notice
of intent to levy. The Appeals officer permitted petitioner to
submit an amended return for each of her taxable years 1993
through 1996. On December 11, 2001, the Appeals officer received
from petitioner an amended return for each of her taxable years
1993 through 1995. On December 18, 2001, the Appeals officer
received from petitioner an amended return for her taxable year
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