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We’ve finished looking at the information you sent
us and we’ve made a decision about your audit reconsid-
eration * * *.
We regret to inform you that we decided that we
should not change the original tax amount. The at-
tached Form 886-A, Explanation of Items, explains how
and why we made our decision.
Attached to each of respondent’s October 30, 2003 letters
was Form 886-A, Explanation of Items, that stated in pertinent
part:
Since you did not provide documentation to verify the
deductions being claimed, we are not changing the
previous determination.
On September 16, 2005, respondent filed notices of Federal
tax lien with respect to petitioner’s taxable years 1995, 1996,
1997, 1999, and 2000.
On September 21, 2005, respondent issued to petitioner a
notice of Federal tax lien filing and your right to a hearing
(notice of tax lien) with respect to his taxable years 1995,
1996, 1997, 1999, and 2000.
On October 17, 2005, in response to the notice of tax lien,
petitioner, through his authorized representative, mailed to
respondent Form 12153, Request for a Collection Due Process
Hearing, and requested a hearing with respondent’s Appeals Office
(Appeals Office).
On February 14, 2006, a settlement officer with the Appeals
Office (settlement officer) held a telephonic Appeals Office
hearing with petitioner’s authorized representative.
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Last modified: May 25, 2011