Glen A. Blair - Page 5




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          petitioner attended.  During the hearing, the Appeals officer               
          provided petitioner with a Form 4340, Certificate of Assessments,           
          Payments, and Other Specified Matters, with regard to his account           
          for 1997.  A copy of the Form 4340, dated October 22, 2001, is              
          part of the record in this case.                                            
               On January 8, 2002, respondent issued to petitioner a Notice           
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330.  The notice stated that the Appeals Office                
          determined that it was appropriate to proceed with the collection           
          of petitioner’s outstanding tax liability for 1997.  On February            
          5, 2002, petitioner filed with the Court a petition for lien or             
          levy action seeking review of respondent’s notice of                        
          determination.2                                                             
               As indicated, respondent filed a motion for summary judgment           
          asserting that there is no dispute as to a material fact and that           
          respondent is entitled to judgment as a matter of law.  In                  
          particular, respondent contends that, because petitioner                    
          acknowledges that he received the notice of deficiency for 1997,            
          he cannot challenge the existence or amount of his underlying tax           
          liability for that year in this proceeding.  Respondent further             
          asserts that the Appeals officer’s review of the transcript of              
          account for 1997 satisfied the verification requirement imposed             



               2  At the time that the petition was filed, petitioner                 
          resided in Las Vegas, Nevada.                                               





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