Robert Conde Del'Giudice - Page 3

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               The petition in this case was filed in response to a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330 (notice of determination).  Pursuant to sections           
          6320(c) and 6330(d), petitioner seeks review of respondent’s                
          determination to proceed with collection of his tax liability for           
          1999.  The issue for decision is whether the Appeals officer                
          abused his discretion in sustaining a proposed levy to collect              
          petitioner’s unpaid 1999 tax liability.                                     
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  At the time the             
          petition in this case was filed, petitioner resided in Buena                
          Park, California.                                                           
               Petitioner, a former software system engineer, is a teacher            
          of mathematics and computer technology in the Los Angeles public            
          school system.  In April of 2002 he married his second wife.                
          Petitioner did not pay Federal withholding taxes on his income              
          for 1999.  He did not file his Federal income tax return for 1999           
          until February 23, 2004.                                                    
               On May 22, 2004, respondent issued to petitioner a notice of           
          intent to levy regarding his unpaid tax liability for 1999.                 
          Petitioner filed a Form 12153, Request for a Collection Due                 
          Process Hearing, dated June 12, 2004, as to 1999, 2000, and 2001.           
          Respondent had sent to petitioner a notice of Federal tax lien              

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