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$3,298.73, $952.97,4 and $489.93.
Petitioner did not file a petition in the Court with respect
to the 2001 notice of deficiency or the 2002 notice of defi-
ciency.
On November 22, 2004, respondent assessed petitioner’s tax,
as well as additions to tax and interest as provided by law, for
each of his taxable years 2001 and 2002. (We shall refer to
those unpaid assessed amounts, as well as interest as provided by
law accrued after November 22, 2004, as petitioner’s unpaid
liabilities for 2001 and 2002.)
On November 22, 2004, respondent issued to petitioner a
notice of balance due with respect to petitioner’s unpaid liabil-
ities for 2001 and 2002.
On April 9, 2005, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to petitioner’s unpaid
liabilities for 2001 and 2002.
On May 9, 2005, in response to the notice of intent to levy,
petitioner filed Form 12153, Request for a Collection Due Process
Hearing (petitioner’s Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office). Petitioner at-
4With respect to the addition to tax under sec. 6651(a)(2),
respondent determined in the 2002 notice of deficiency that that
“addition to tax will continue to accrue from the due date of the
return at a rate of 0.5 percent each month, or fraction thereof,
of nonpayment, not exceeding 25 percent.”
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Last modified: November 10, 2007