-4-
1996. In petitioner’s 1993 amended return, petitioner reported
total tax of $3,956 and tax withheld of $4,376 and claimed an
overpayment and a refund of $420. In petitioner’s amended return
for 1994, petitioner reported total tax of $2,284 and tax with-
held of $4,318 and claimed an overpayment and a refund of $2,034.
In petitioner’s 1995 return, petitioner reported total tax of
$3,671 and tax withheld of $4,323 and claimed an overpayment and
a refund of $652. In petitioner’s 1996 amended return, peti-
tioner reported total tax of $2,314 and tax paid of $2,812 and
claimed an overpayment and a refund of $498.
On February 19, 2002, the Appeals Office issued to peti-
tioner a notice of determination with respect to the notice of
intent to levy. In the notice of determination, respondent
sustained the proposed collection action.
Thereafter, respondent agreed to accept the information
reported in petitioner’s 1993 amended return, 1994 amended
return, 1995 amended return, and 1996 amended return, except for
the amount of tax paid reported in petitioner’s 1996 return.2
With respect to petitioner’s taxable years 1993, 1994, and 1995,
the respective taxes withheld exceed the respective total taxes
2In her 1996 amended return, petitioner reported tax paid of
$2,812, which she claimed consisted of tax withheld of $1,008 and
other tax payments of $1,804. Respondent’s records indicate that
the tax payments for petitioner’s taxable year 1996 total $1,171,
which consisted entirely of tax withheld and which is the total
amount of tax payments that petitioner reported in her 1996
return filed on Apr. 15, 1997.
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