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for decision is whether respondent’s determination to proceed
with collection action should be sustained.
FINDINGS OF FACT
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Lafayette,
California.
Petitioner failed to timely file her Federal income tax
returns for 1994, 1995, 1996, and 1997. Respondent filed
substitutes for returns for each of those years. During the
years at issue, petitioner was employed by the County of Contra
Costa, California (County). She earned gross income from her
employment of $40,317 in 1994, $41,961 in 1995, $46,906 in 1996,
and $58,042.16 in 1997.
Collection Activity for Prior Tax Years
Respondent, having previously warned petitioner of impending
wage attachments, sent notices of levy to the County with respect
to her Federal income taxes for 1990, 1992, and 1993. The notice
of levy dated December 15, 1997, was in the amount of $4,605.49
and the notice of levy dated January 15, 1998, was in the amount
of $4,639.01.1 County technicians responsible for tracking
garnishments and wage assignments prepared contemporaneous
1Both notices of levy concerned petitioner’s tax liabilities
for 1990, 1992, and 1993, but the second notice was for a
slightly larger amount due, apparently, to additional interest.
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