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ORDERED that in support of the statement described
above, respondent shall submit a certified copy of a
current certificate of assessments and payments for
each of the above-referenced years.
In response to the Order, respondent filed Respondent’s
Supplement, which contains detailed and comprehensive
explanations of the matters raised in the Order.
Respondent’s Supplement demonstrates the differences between
the assessed balances of tax and penalties, the late-paying
penalties under section 6651(a)(3) and accrued interest,
reflected in the Levy Notice for the tax years 1988 to 1992
inclusive, and the same categories of items currently assessed or
accrued. As of November 18, 2005, petitioner owed $111,407.46,
rather than $123,226.56, the total amount asserted in the Levy
Notice, a difference of $11,819.10 in petitioner’s favor. In
paragraph 96 of Respondent’s Supplement, respondent concedes that
he can collect only the current amount petitioner owes (i.e., the
net assessed amounts of tax, including section 6651(a)(1)
penalty, plus interest and section 6651(a)(3) nonpayment penalty
accrued to date of payment).
Interest and the section 6651(a)(3) penalty (up to the
limitation contained in that section) continue to accrue until
petitioner makes payments of the amounts assessed for the
aforementioned years. Petitioner did not analyze respondent’s
carefully detailed computations contained in Respondent’s
Supplement, but instead made bald allegations that respondent
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