-2- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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