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that day, and they discussed petitioner’s tax accounts over the
telephone. Petitioner agreed that he owed the liabilities for
taxable years 1997 and 1998 and did not dispute the accuracy of
the assessed amounts. Petitioner likewise acknowledged that he
had not filed tax returns for 2001, 2002, and 2003. Petitioner
stated that he had an appointment with a return preparer the week
of November 14, 2005. Ms. Craca set a deadline of December 5,
2005, for petitioner to provide her with the returns.
Ms. Craca did not receive any correspondence, tax returns,
or financial information from petitioner by December 5, 2005.
Ms. Craca verified that she had no prior involvement with the
unpaid taxes at issue and that all legal and procedural
requirements for proceeding with a lien had been met. Ms. Craca
concluded that, because petitioner had not filed the required
returns and had not provided the requested financial information,
she could not consider collection alternatives. Ms. Craca then
closed the case, sustaining the proposed lien. Respondent sent
petitioner a Notice of Determination dated December 22, 2005.
By letter dated January 16, 2006, petitioner’s probation
officer3 submitted a letter to the Court, requesting that
respondent schedule a redetermination hearing, which letter the
3Petitioner spent 15 months in prison for filing fraudulent
tax returns and fraud. He is now on supervised release for a
term of 3 years.
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