Russel S. Bankson - Page 3

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               This proceeding arises from a petition for judicial review             
          filed in response to a Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 (notice of              
          determination) sent to petitioner on November 4, 2004.  The issue           
          for decision is whether respondent abused his discretion in                 
          sustaining a notice of Federal tax lien filed against petitioner.           
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  The record consists of the stipulation of facts and                 
          supplemental stipulation of facts with attached exhibits,                   
          additional exhibits introduced at trial, and the testimony of               
          petitioner.  At the time of filing the petition, petitioner                 
          resided in Emeryville, California.                                          
               Petitioner filed Federal income tax returns for the taxable            
          years 2000 and 2001 but did not pay the taxes reported thereon.             
          Respondent assessed the taxes shown on the returns, as well as              
          related penalties and interest, and filed a notice of Federal tax           
          lien against petitioner on May 29, 2003, in the total amount of             
          $13,220.86.  Respondent sent petitioner a Notice of Federal Tax             
          Lien Filing and Your Right to a Hearing Under IRC 6320 on June 3,           
          2003.                                                                       
               Petitioner timely submitted a Form 12153, Request for a                
          Collection Due Process Hearing.  Petitioner also submitted an               
          offer-in-compromise (OIC), in which he offered to pay $3,800 to             






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