Lynda Diane Sampson-Gray - Page 3

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               Pursuant to section 6330(d), petitioner seeks review of an             
          Appeals Office determination sustaining a levy on petitioner’s              
          State income tax refund.  The issue for decision is whether                 
          respondent abused his discretion in issuing the notice of                   
               Petitioner filed her 1991, 1992, and 1997 Federal income               
          tax returns late.  Respondent assessed the taxes shown on the               
          returns and related additions to tax for failure to timely file             
          returns and pay taxes due.                                                  
               On or about October 1, 2002, respondent levied $537.32 of              
          petitioner’s State tax refund.  Respondent recorded this amount             
          as a payment on petitioner’s 1991 account, along with various               
          other payments, generating overpayment credits which respondent             
          transferred to petitioner’s 1992 and 1997 accounts.                         
               On February 3, 2003, respondent issued to petitioner a                 
          notice indicating that the IRS had levied $537.52 of her State              
          tax refund to pay her unpaid Federal tax (no year specified).               
          Petitioner timely mailed to respondent a request for a hearing              
          under section 6330 as to the levy.                                          
               Following exchanges of correspondence and a conference                 
          between petitioner and representatives of respondent’s Appeals              
          Office, on April 5, 2004, the Appeals Office issued a Notice of             
          Determination, which states that it relates to petitioner’s 1997            

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