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taxable years 1995, 1996, and 1997, respectively, and that
respondent was preparing to collect the same. The notice stated
that petitioner would be given 30 days to request an
administrative hearing with respondent's Appeals Office.
On October 19, 1999, petitioner filed a request for a
collection hearing, Form 12153, with respondent's Appeals Office
stating that he was not liable for the taxes set forth in
respondent’s notice of intent to levy.
On September 28, 2000, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (the determination
letter) stating that respondent intended to proceed with
collection for the taxable years 1995, 1996, and 1997. The
determination letter stated further that because petitioner had
received a notice of deficiency for the taxable years 1995 and
1996, petitioner was not permitted to challenge his tax
liabilities for those years in proceedings before the Appeals
Office.
On October 30, 2000, petitioner filed with the Court a
petition for review of respondent's determination to proceed with
collection for the taxable years 1995, 1996, and 1997. The
petition includes allegations that petitioner is not liable for
the deficiencies for each of the years in question. In response,
respondent filed a Motion To Dismiss The Tax Years 1995 And 1996
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