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The issue for decision is whether respondent’s Appeals
Office abused its discretion in sustaining respondent’s notice of
levy.
Background
The essential facts of this case were stipulated and are so
found.
At the time the petition was filed, petitioner resided in
Dallas, Texas.
For 1997, 1998, 1999, 2000, and 2001, petitioner failed to
file individual Federal income tax returns.
On or about October 17, 2003, respondent mailed to
petitioner notices of deficiency determining deficiencies in
petitioner’s Federal income taxes for 1997 through 2000 of
$6,305, $4,986, $4,234, and $33,831, respectively, and for 2001
an amount not disclosed in the record.
On January 14, 2004, in docket Nos. 1053-04, 1054-04,
1055-04, and 1056-04, petitioner filed separate petitions
relating to the above notices of deficiency for 1997 through
2000.
Petitioner did not file a petition with regard to the above
notice of deficiency for 2001, and on November 29, 2004,
respondent assessed the tax deficiency against petitioner for
2001.
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Last modified: November 10, 2007