Warren L. Owens - Page 3

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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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