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no genuine issue of material fact remains for trial. At the time
petitioner filed his petition to this Court, he resided in
Salinas, California.
On August 14, 2000, respondent filed a Notice of Federal Tax
Lien, Form 668(Y)(c), with the County Recorder of Monterey
County, Salinas, California. The lien was filed with respect to
unpaid income taxes of $10,239.52 for taxable years 1990, 1991,
1992, 1993, and 1994.2 On August 18, 2000, respondent issued a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320, Letter 3172 (ALS), to petitioner. The notice
informed petitioner of his right to a hearing before the IRS
Appeals Office. On September 21, 2000, petitioner filed a timely
Form 12153, Request for a Collection Due Process Hearing.
Attached to petitioner’s Form 12153 was a 12-page document in
which petitioner raised challenges to the lien filing.
1(...continued)
the Internal Revenue Code currently in effect, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2Petitioner did not file tax returns for taxable years 1990
through 1994. Petitioner has addressed several letters to
members of the Federal Government arguing that the 16th Amendment
was fraudulently certified as ratified by the States, and the IRS
is without the constitutional power to assess and collect taxes.
These arguments, as articulated by petitioner, have been
correctly described as tax protester gibberish. See Crain v.
Commissioner, 737 F.2d 1417, 1418 (5th Cir. 1984); Williams v.
Commissioner, 114 T.C. 136, 144 (2000); Nagy v. Commissioner,
T.C. Memo. 1996-24; Black v. Commissioner, T.C. Memo. 1995-560;
Olsen v. Commissioner, T.C. Memo. 1995-471; Pabon v.
Commissioner, T.C. Memo. 1994-476.
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