Howard Goza - Page 4

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          is not liable for the taxes in question based on a number of                   
          frivolous constitutional arguments.                                            
               On February 17, 1999, respondent mailed a final notice of                 
          intent to levy to petitioner pursuant to section 6331.  The                    
          notice stated that petitioner owed taxes, penalties, and interest              
          totaling $23,816.20, $22,653.89, and $21,658.74, for the taxable               
          years 1994, 1995, and 1996, respectively, and that respondent was              
          preparing to collect these amounts.  The notice stated that                    
          petitioner could request a "Collection Due Process Hearing" with               
          respondent's Appeals Office.                                                   
               On March 9, 1999, petitioner returned the notice of intent                
          to levy to respondent with the same handwritten statement                      
          appearing on the notice of deficiency.  On August 24, 1999,                    
          respondent's Atlanta Appeals Office issued a notice of                         
          determination to petitioner which stated in pertinent part:                    
               We have reviewed the proposed collection action for the                   
               periods [1994, 1995, and 1996].  This letter is your                      
               legal Notice of Determination as required by law. * * *                   
               *        *        *        *        *        *        *                   
               Summary of Determination:                                                 
               It has been determined that the requirements of all                       
               applicable laws and administrative procedures have been                   
               As you were advised in our letter dated July 6, 1999,                     
               challenges to the underlying liability may only be                        
               raised as an issue if you did not receive a statutory                     
               notice of deficiency or did not otherwise have an                         
               opportunity to dispute the liability.  You did receive                    
               a statutory notice of deficiency in this case.  You                       
               were also informed that a hearing is not available for                    

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