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respondent a Form 12153, Request for a Collection Due Process
Hearing, challenging respondent’s Notice of Federal Tax Lien
Filing. Petitioner’s request stated that he is not a taxpayer
and that the payment of Federal income taxes constitutes a gift
to the United States.
D. The Appeals Office Hearing
On March 23, 2001, Appeals Officer Angela M. Carmouche (the
Appeals officer) conducted an Appeals Office hearing that
petitioner attended. During the hearing, the Appeals officer
provided petitioner with transcripts of account (MFTRAX) with
regard to his taxable years 1995 and 1996. By letter dated
April 23, 2001, the Appeals Office forwarded to petitioner Forms
4340, Certificate of Assessments, Payments, and Other Specified
Matters, with regard to his taxable years 1995 and 1996. A copy
of the Forms 4340, dated March 27, 2001, are attached to
respondent’s Motion for Summary Judgment, which was served on
petitioner. The Appeals Office also provided petitioner with a
copy of the Court’s opinion in Pierson v. Commissioner, 115 T.C.
576 (2000).
E. Respondent’s Notice of Determination
On July 2, 2001, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. The notice stated that the Appeals Office had
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