Terry Hiram Pierson - Page 1

                                   115 T.C. No. 39                                    

                               UNITED STATES TAX COURT                                

                         TERRY HIRAM PIERSON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8650-00L.                Filed December 14, 2000.           

                    R issued a notice of deficiency to P for the                      
               taxable year 1988, but P did not file a petition for                   
               redetermination with the Court.  R subsequently issued                 
               a notice of intent to levy.  P requested and received                  
               an administrative review of the proposed collection                    
               action.  R issued a notice of determination to P                       
               stating that all applicable laws and administrative                    
               procedures had been met and that collection would                      
               proceed; R further advised P that a challenge to the                   
               underlying liability would not be considered because P                 
               had received a notice of deficiency.  P filed an                       
               imperfect petition with the Court for review of                        
               respondent’s determination to proceed with collection.                 
               However, the petition did not contain any specific                     
               allegations.  R moved to dismiss for failure to state a                
               claim.  The Court then directed P to file a proper                     
               amended petition, but P failed to do so.  Rather, P                    
               filed a statement asserting that he is not liable for                  
               the underlying liability based on frivolous and                        
               groundless arguments.                                                  

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