John Thurman Horejs - Page 5

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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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