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petitioner should file tax returns for the years in issue. A
hearing was conducted with the Appeals officer, and petitioner
presented arguments that he was not subject to income tax and
that there were defects in respondent’s procedures.
On December 16, 2003, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. The notice states that the Appeals
Office determined that it was appropriate to proceed with
collection for 1996 through 2000 as follows:
Unpaid
Year Liability1
1996 $11,562.07
1997 41,312.05
1998 31,040.43
1999 40,107.43
2000 25,793.49
1 Calculated through Nov. 30, 2003.
The letter advised, among other things, that petitioner could be
subject to sanctions pursuant to section 6673(a) for instituting
or maintaining an action primarily for delay or taking a position
that is frivolous or groundless.
On January 12, 2004, petitioner filed with the Court a
petition for lien or levy action seeking review of respondent’s
notice of determination. At the time that the petition was
filed, petitioner resided in Maitland, Florida.
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