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collection by levy of petitioner’s Federal income tax liability
for 1988 to 1992, inclusive, plus accrued interest and failure to
pay penalty under section 6651(a)(3). Unless otherwise
indicated, all section references are to sections of the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Petitioner resided in Reston, Virginia, at the time the petition
was filed.
Background
Under “Brief Background,” the notice of determination
states, among other things, that
The outstanding tax liabilities are the result of TC
300 additional tax assessments because Mr. Reese was a
non-filer.[1] When the required Notices of Deficiencies
[for 1988 to 1992, inclusive,] were issued, * * * [Mr.
Reese] petitioned Tax Court. The TC 300 assessments
and all applicable penalties and interest are in
accordance with the Tax Court Decision documents for
each year.
Under Relevant Issues Presented by the Taxpayer, the Notice
states that
IRC 6330(c) allows the taxpayer to raise any relevant
issue relating to the unpaid tax. Form 12153 as
prepared by Mr. Reese claims that the amounts
outstanding are in error: that the Philadelphia
Service Center transposed numbers from the Tax Court
Decision Documents, and have [sic] refused to abate the
incorrect amounts.
1TC 300, 1 Audit, Internal Revenue Manual (CCH), exhibit
4.4.1-1, at 7425, is a so-called transaction code number used
internally by the Internal Revenue Service. It has no
significance for purposes of this case.
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