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is not reviewable by any other court, and this opinion shall not
be treated as precedent for any other case.
The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination). Pursuant to section
6330(d), petitioner seeks review of respondent’s proposed levy
action with respect to his income tax liability for tax year
1999. The issue for decision is whether respondent’s
determination to proceed with the proposed levy action for tax
year 1999 was an abuse of discretion.
Background
At the time petitioner filed the petition, he resided in
Houston, Texas. Petitioner filed a Federal income tax return for
the tax year 1999 which showed tax of $4,587, a withholding
credit of $1,922, and a balance due of $2,665. Respondent
assessed the tax shown on petitioner’s 1999 return, plus
additions to tax and interest. Thereafter, respondent audited
petitioner’s 1999 return, determined a deficiency of $1,170, and
issued a notice of deficiency. Petitioner filed a petition with
this Court with respect to the 1999 tax year, but the case for
that year was never tried because the parties agreed to a
stipulated decision, which was entered on February 28, 2003. In
the decision document, the parties stipulated that there was a
deficiency of $1,170 for 1999. The parties further stipulated
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