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must decide is whether respondent’s Appeals Office abused its
discretion in determining to proceed with collection of
petitioner’s tax liability for taxable years 1999, 2001, and
2002. For the reasons stated below, we shall grant respondent’s
motion for summary judgment and to impose a penalty pursuant to
section 6673.
Background
At the time of filing the petition in the instant case,
petitioner resided in Melbourne, Florida. Petitioner failed to
file Federal income tax returns or pay tax for taxable years 1999
through 2003. Respondent sent petitioner a notice of deficiency
for each year. Petitioner petitioned this Court regarding
taxable year 2003. That case is at docket No. 14262-05.
Petitioner failed to petition this Court regarding any other
taxable years, and accordingly, respondent assessed deficiencies
plus section 6651(a)(1) and 6654(a) additions to tax and interest
for taxable years 1999, 2001, and 2002. Petitioner’s current
liabilities, including interest through the trial date of October
16, 2006, for the years in issue are $38,324.42, $66,315.10, and
$72,286.30, respectively.
On March 28, 2005, respondent sent petitioner a Letter 1058,
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing, with respect to the years in issue in the instant case.
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