Greg Griffin - Page 4




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          deficiency with respect to 1988 and 1989.  Petitioner did not               
          file timely petitions with this Court in response to the notices            
          of deficiency, and the deficiencies were assessed.                          
               On March 17, 1997, petitioner filed his 1988 and 1989                  
          Federal income tax returns.  Respondent abated the assessments              
          down to the amount shown on petitioner’s returns.  Thereafter,              
          petitioner requested audit consideration, and respondent                    
          initiated an examination of petitioner’s return.  During the                
          examination, the revenue agent proposed additional assessments              
          for each year, and petitioner signed Forms 4549-CG on June 21,              
          1999.  The Forms 4549-CG show deficiencies of $3,036 and $2,695             
          for 1988 and 1989, respectively.                                            
               Respondent issued a Letter 1058, Final Notice of Intent to             
          Levy and Notice of Your Right to a Hearing, on June 23, 2005.  On           
          June 24, 2005, respondent’s revenue officer filed an NFTL at the            
          County Recorder, San Diego, California.  On June 29, 2005,                  
          respondent’s revenue officer issued a Letter 3172(DO), Notice of            
          Federal Tax Lien Filing and Your Right to a Hearing under IRC               
          6320.  Petitioner submitted a Form 12153, Request for a                     
          Collection Due Process Hearing, with respect to both notices.               
          Respondent consolidated the hearings into one proceeding.  In               
          communications with the Appeals officer, petitioner sought to               
          challenge the underlying tax liabilities and would not offer any            
          alternatives to collection.  Because petitioner intended to seek            







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