Robert D. Hill - Page 4




                                         -4-                                          
               On April 7, 2001, petitioner filed an amended U.S.                     
          individual income tax return for 1995.  Petitioner reported zero            
          income and zero taxes due, explaining the changes: “Due to                  
          ignorance I reported as income sources of income as being income            
          itself, when in fact I had no statutory income to report.”                  
               On October 12, 2001, Appeals Officer Julienne Peterson held            
          with petitioner a hearing under section 6330.  At the hearing,              
          the Appeals officer provided petitioner with Forms 4340,                    
          Certificates of Assessments, Payments and Other Specified                   
          Matters.  The Forms 4340 were dated August 29, 2001, and were for           
          1993, 1995, and 1996.  The Appeals officer discussed with                   
          petitioner the case of Pierson v. Commissioner, 115 T.C. 576                
          (2000), and provided petitioner with a copy of the Court’s                  
          opinion in that case.  The Appeals officer also gave petitioner a           
          copy of this Court’s opinion in Davis v. Commissioner, T.C. Memo.           
          2001-87.                                                                    
               On January 3, 2002, respondent issued to petitioner a Notice           
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330 for 1993, 1995, and 1996.  This notice reflected           
          the determination of Appeals to sustain the lien and proposed               
          levy.                                                                       
                                     Discussion                                       
               Summary judgment is intended to expedite litigation and                
          avoid unnecessary and expensive trials.  Fla. Peach Corp. v.                






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