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June 2006.1 The issue for decision is whether respondent abused
his discretion in sustaining a notice of Federal tax lien filed
against petitioner.
Background
Some of the facts have been stipulated, and they are so
found. The record consists of the stipulation of facts with
attached exhibits, additional exhibits introduced at trial, and
the testimony of petitioner. At the time the petition was filed,
petitioner resided in Fort Myers, Florida.
Petitioner filed tax returns for 1996 and 1997 but did not
pay all the tax reported thereon. Respondent issued petitioner a
notice of deficiency for the taxable year 1996. Petitioner did
not file a petition for judicial review, and respondent assessed
the additional tax shown on the notice. Respondent accepted
petitioner’s return for 1997 and therefore did not issue a notice
of deficiency for that year.
Respondent issued petitioner a Notice of Intent to Levy and
Notice of Your Right to a Hearing (notice of intent to levy) for
the taxable years 1996 and 1997 on February 23, 2004. Petitioner
did not request an administrative hearing in response to the
notice of intent to levy.
1 Section references are to the Internal Revenue Code and
Rule references are to the Tax Court Rules of Practice and
Procedure.
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