Patricia Agnes Williams, Debbie Wales, Next Friend - Page 4

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          Soon after the case was transferred, the IRS requested that                 
          petitioner and her spouse consent to extending the period of                
          limitations for assessment of the tax due on the 1990 tax return.           
          When they refused to consent to the extension, the IRS disallowed           
          their claimed Schedule C expenses due to lack of substantiation.            
          The disallowance of the Schedule C expenses, which also led to              
          the disallowance of a small amount of itemized deductions on                
          Schedule A, resulted in a deficiency of $3,204.                             
               Respondent prepared a statutory notice of deficiency dated             
          July 22, 1997, for issuance to petitioner and her spouse for                
          1990, reflecting a deficiency of $3,204 and additions to tax                
          under section 6651(a)(1) and (2) and an accuracy-related penalty            
          under section 6662.  No petition for a redetermination of the               
          deficiency was filed in this Court, and the IRS assessed the                
          deficiency, additions, and penalty on December 19, 1997.                    
               In September of 1999 the IRS sent to petitioner and her                
          spouse Letter 1058, Final Notice of Intent to Levy and Notice of            
          Your Right to a Hearing.  The letter notified them that the IRS             
          intended to levy on their property and rights to property to                
          collect their unpaid liabilities for 1990, and of their right to            
          request a hearing with the Appeals Office before execution of the           
          levy.  Although petitioner received a copy of the notice of                 
          intent to levy and right to a hearing, she did not request a                
          hearing with Appeals.                                                       

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