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the Treasury, and Charles O. Rossotti, Commissioner of Internal
Revenue.
Petitioner knew that he had the right to contest
respondent’s deficiency determination by filing a petition for
redetermination with this Court.3 However, petitioner chose not
to do so. Accordingly, on May 8, 2000, respondent assessed the
determined deficiency and accuracy-related penalty, as well as
statutory interest. On that same day, respondent sent petitioner
a notice of balance due, informing petitioner that he had a
liability for 1997 and requesting that he pay it. Petitioner
failed to do so.
C. Respondent’s Final Notices and Petitioner’s Response
One year later, on May 8, 2001, respondent sent petitioner a
Final Notice-–Notice of Intent to Levy and Notice of Your Right
to a Hearing (the Final Notice). The Final Notice was issued in
respect of petitioner’s outstanding tax liability for 1997. On
May 15, 2001, respondent sent petitioner a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 in respect
of his outstanding liability for 1997.
3 In this regard, petitioner’s letter dated Jan. 26, 2000,
stated in pertinent part:
According to your “Deficiency Notice” of the above
date (cover sheet attached), there is an alleged
deficiency with respect to my * * * 1997 income tax
* * * and if I wanted to “contest this deficiency
before making payment,” I must “file a petition with
the United States Tax Court.”
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