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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
met.
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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