Judy Hedrick Blosser - Page 2

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          Appeals Office abused its discretion in sustaining respondent’s             
          proposed levy action against petitioner to collect income tax               
          liabilities for the taxable years 1994, 1995, and 1996 and                  
          denying petitioner’s request for alternative collection methods.            
          We conclude that there are no genuine issues as to any material             
          facts, a decision may be rendered as a matter of law, and the               
          Appeals Office abused its discretion.                                       
               At the time she filed her petition, petitioner resided in              
          Harrisonburg, Virginia.                                                     
               Petitioner did not file Federal income tax returns for                 
          taxable year 1994, 1995, or 1996.  Respondent issued notices of             
          deficiency for those years and determined tax deficiencies of               
          $2,892, $6,368, and $2,937, respectively.                                   
               On November 22, 2005, respondent mailed to petitioner a                
          Letter L-1058, Final Notice of Intent to Levy and Notice of Your            
          Right to a Hearing, informing petitioner that respondent proposed           
          to levy on her property to collect Federal income taxes owed for            
          1994, 1995, and 1996.  After assessing penalties and interest and           
          applying withholding credits, respondent determined that                    
          petitioner owed a total of $26,011.04.                                      
               On December 9, 2005, petitioner timely filed a Form 12153,             
          Request for a Collection Due Process Hearing, regarding the                 
          proposed levy.  Petitioner claimed that she could not afford to             

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