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Arnold Rd., Memphis, Tennessee 38115 (the Knight Arnold Rd.
address).
By letter dated July 6, 1995, petitioner mailed the notices
of deficiency back to respondent marked "Refusal For Cause
Without Dishonor U.C.C. 3-501". Petitioner's July 6, 1995,
letter, to which an "Affidavit and Declaration of Truth" was
appended, contained various tax protester arguments.
On September 25, 1996, petitioner filed two separate
petitions with the Court contesting the determinations made by
respondent in the above-described notices of deficiency. The
petitions arrived at the Court in an envelope bearing a U.S.
Postal Service postmark date of September 23, 1996. Petitioner
indicated on each of the petitions that his address was the
Knight Arnold Rd. address.
On October 16, 1996, petitioner filed a Motion to Restrain
Assessment, Levy, Lien, and Collection in each docket. Attached
to petitioner's motions are copies of a Notice of Levy and a
Notice of Federal Tax Lien. These documents indicate that
respondent is attempting to collect the deficiencies and the
additions to tax that she determined are owing from petitioner
for the taxable years 1989 through 1992. Petitioner contends
that respondent's collection efforts are improper because
petitioner filed petitions with the Court contesting respondent's
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Last modified: May 25, 2011