William M. Hezel - Page 3

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          Arnold Rd., Memphis, Tennessee 38115 (the Knight Arnold Rd.                 
               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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