Marvin Silverman - Page 2




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                                     Background                                       
               At the time he filed the petition, petitioner resided in               
          Beverly Hills, California.                                                  
               On January 11, 1995, respondent mailed petitioner a notice             
          of deficiency determining deficiencies and additions to tax for             
          1989 and 1990.  On September 22, 2003, respondent mailed                    
          petitioner a notice of deficiency determining a deficiency and              
          additions to tax for 1998.  The record does not establish that              
          petitioner received either notice of deficiency.                            
               On June 29, 2001, petitioner filed a petition pursuant to              
          chapter 13 of the U.S. Bankruptcy Code, 11 U.S.C. ch. 13, in the            
          U.S. Bankruptcy Court for the Central District of California.               
          In the bankruptcy case, respondent filed a proof of claim and               
          multiple amended proofs of claim against petitioner regarding               
          petitioner’s assessed income tax liabilities for 1989, 1990, and            
          1998.  On May 26, 2004, petitioner’s bankruptcy case was                    
          dismissed.                                                                  
               On December 30, 2004, respondent sent petitioner a Final               
          Notice-–Notice of Intent to Levy and Notice of Your Right to a              
          Hearing regarding petitioner’s outstanding 1989, 1990, and 1998             
          income tax liabilities.  On January 18, 2005, petitioner sent               
          respondent a Form 12153, Request for a Collection Due Process               
          Hearing (hearing request).  Petitioner attached to the hearing              








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