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sections 6320 and 6330 and the issues that he could raise, and
(2) stating that respondent would not consider challenges based
on constitutional, political, or moral grounds. Respondent
enclosed a copy of Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters, for petitioner’s 1995-2000
tax years.
On May 19, 2004, Appeals Officer Davida S. Parker (Parker)
told petitioner that he had timely appealed the January 20, 2004,
notice of Federal tax lien, but that he had not timely appealed
the lien filed on September 28, 2000. Parker mistakenly believed
that petitioner had not timely requested an administrative
hearing with respect to his Federal income tax liability for
1995-96, and she told him that he could have a so-called
equivalent hearing instead. See sec. 301.6320-1(i)(1), Proced. &
Admin. Regs. Parker offered to discuss the case with him by
telephone on June 23, 2004.
Petitioner wrote Parker on May 19, 2004, requesting a face-
to-face hearing and copies of documents verifying assessment of
taxes and penalties. Petitioner told Parker that he intended to
bring a court reporter to the hearing and record it.
In a June 11, 2004, letter to Parker petitioner alleged that
(1) he was entitled to a face-to-face hearing, (2) payment of
taxes is voluntary, (3) his taxes had not been properly assessed,
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