William Reese - Page 12

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               As already noted, the only issue raised by petitioner at the           
          Appeals hearing was that the Philadelphia Service Center had                
          transposed numbers from the Tax Court decision documents and                
          refused to abate the incorrect amounts.  The Appeals officer                
          determined that the tax, including penalties, reflected in the              
          Tax Court decision documents had been correctly assessed, but               
          that petitioner had not been credited with withholding tax for              
          1989, 1990, and 1992.  Accordingly, the Appeals officer made                
          three adjustment documents for crediting petitioner with the                
          withholding taxes.                                                          
               Because petitioner in his petition persisted in maintaining            
          that the IRS had made excessive and wrongful assessments, the               
          Court, as already discussed, directed respondent, among other               
          things, to explain how the liability for each year was computed,            
          and to demonstrate the allowance of the 1989, 1990, and 1992                
          withholdings, which were not taken into account in respondent’s             
          Levy Notice, dated March 22, 2004.  Respondent’s notice of                  
          determination, issued after the Levy Notice, properly reflects              
          the allowance of the withholding credits.                                   
               In petitioner’s “Opposition” to Respondent’s Supplement, he            
          makes no attempt whatsoever to demonstrate why he believes                  
          respondent transposed decision document numbers, or why                     
          respondent’s assessments are incorrect.  Instead he persists in             







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