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With third-party information returns and Bureau of Labor
Statistics figures, respondent reconstructed petitioner’s 1992
and 1993 income.
On November 27, 1995, based on respondent’s reconstruction
of petitioner’s income, respondent issued to petitioner a notice
of deficiency relating to 1992 and 1993 in which respondent
determined the above income tax deficiencies and additions to tax
for failure to file and failure to pay estimated income tax.
Petitioner received respondent’s notice of deficiency.
Petitioner, however, did not petition this Court to redetermine
the income tax deficiencies and additions to tax set forth
therein.
On June 17, 1996, respondent assessed the above income tax
deficiencies, additions to tax for failure to file and failure to
pay estimated income taxes, and related interest.
On December 24, 2004, respondent mailed to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing (levy notice) relating to the above unpaid liabilities.
On December 30, 2004, petitioner requested a hearing with
respondent’s Appeals Office with respect to the proposed levy
action. On June 7, 2005, respondent’s Appeals officer held a
telephone hearing with petitioner. During the hearing,
petitioner did not propose collection alternatives to
respondent’s Appeals officer. Instead, petitioner presented
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