Robert D. Hill - Page 3




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          with the lien notice was a copy of Form 12153, Request for a                
          Collection Due Process Hearing.  On November 30, 2000, respondent           
          received from petitioner the completed Form 12153 requesting the            
          hearing regarding the lien.                                                 
               On December 14, 2000, petitioner filed an amended U.S.                 
          individual income tax return for 1996.  Petitioner reported that            
          he had zero income and zero taxes due, explaining the changes:              
          “Due to ignorance I reported as income sources of income as                 
          income itself when in fact I had no statutory income tax to                 
          report.”   He attached to the amended return a declaration                  
          stating in part that “this return is not being filed                        
          voluntarily,” petitioner “had ‘zero’ income according to the                
          Supreme Court’s definition of income”, and petitioner “can only             
          swear to having ‘zero’ income for 1996.”                                    
               On March 28, 2001, respondent mailed to petitioner a “Final            
          Notice - Notice of Intent to Levy and Notice of Your Right to a             
          Hearing” (final levy notice).  The final levy notice pertained to           
          the subject years and informed petitioner of (1) respondent’s               
          intention to levy under section 6331 and (2) petitioner’s right             
          under section 6330 to a hearing with respondent’s Office of                 
          Appeals (Appeals).  Enclosed with the final levy notice was a               
          copy of Form 12153.  On April 2, 2001, petitioner sent to                   
          respondent the completed Form 12153 requesting the hearing                  
          regarding the levy.                                                         






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