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proceeding arises from a petition for judicial review filed in
response to a Determination Letter Concerning Collection
Action(s) Under Section 6320 and/or 6330. The issue for decision
is whether respondent may proceed with collection action as so
determined.
Background
On September 25, 1998, the Internal Revenue Service (IRS)
sent to petitioner a letter indicating that the agency had no
record of receiving Federal income tax returns from petitioner
for 1991, 1994, 1995, and 1996, and proposing taxes and penalties
or additions to tax based upon records received from third-party
payers. The letter was sent to 12079 Plainview, Detroit, MI
48228, and invited a response from petitioner within 30 days.
The letter listed “Stop 822 M. HOWARD” as the IRS person to
contact. On or about November 23, 1998, the IRS received from
petitioner a copy of a Form 1040, U.S. Individual Income Tax
Return, for 1992. The address shown on the Form 1040 and the
return address on the envelope in which it arrived was 12079
Plainview, Detroit, MI 48228. Enclosed with the return was a
note from petitioner directed to “STOP 822 M. HOWARD” stating:
“THIS A COPY OF THE ORIGINAL TAX FILED IN 1996. I AM SENDING 91,
93, 94, 95, & 96”. Petitioner’s signature on the Form 1040, and
that of the return preparer, was dated September 27, 1996.
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