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advised the Appeals Officer that he did not believe that wages
are income.2 At that hearing, petitioner raised various matters
with the Appeals Officer relating to why he had to pay tax, why
he had to file a return, who had the authority to sign a notice
of deficiency, and what provision of the law made him liable for
tax.
At the conclusion of the February 12, 2001 Appeals Office
hearing, the Appeals Officer advised petitioner that she intended
to sustain the proposed levy action and that he would have the
right to appeal her decision to this Court.
On February 21, 2001, respondent’s Appeals Office sent
petitioner a “NOTICE OF DETERMINATION CONCERNING COLLECTION
ACTION(S) UNDER SECTION 6320 and/or 6330" with respect to his
taxable years 1994 and 1996 (notice of determination). The
notice of determination stated in pertinent part: “If you want
to dispute this determination in court, you must file a petition
with the United States Tax Court for a redetermination within 30
days from the date of this letter.”
On April 2, 2001, petitioner filed a petition in response to
the notice of determination. That petition was mailed to the
2At the hearing that the Court held on petitioner’s motion,
petitioner conceded that he received Form W-2 for each of the
years 1994 and 1996 and that each of those forms correctly
reflected the amount of wages that he received during each of
those years. According to petitioner, Form 1040A that he pre-
pared for each of the years 1994 and 1996 reported $0 of wage
income because wages are not income.
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