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FINDINGS OF FACT
Some facts were stipulated. We incorporate by this
reference the parties’ stipulation of facts and the accompanying
exhibits. Petitioner resided in Orofino, Idaho, when the
petition in this case was filed.
Petitioner failed to file income tax returns for 1992
through 1995. Respondent prepared substitute returns for each
year at issue. On March 28, 1997, a statutory notice of
deficiency was issued to petitioner for 1992, and statutory
notices of deficiency for 1993, 1994, and 1995 were issued to
petitioner on October 24, 1997. Respondent assessed $122,183.42
of income tax, penalties, and interest against petitioner for the
years at issue.
On January 11, 2000, respondent issued a Final Notice of
Intent to Levy and Notice of Your Right to a Hearing to
petitioner. Petitioner timely requested a hearing. In his
request for a hearing, petitioner raised a single argument:
I do not agree with the collection action of
levy and notice of intent to levy [notice
date]. The basis of my complaint is what I
believe to be the lack of a valid summary
record of assessment pursuant to 26 CFR �
301.6203-1. Without a valid assessment there
is no liability. Without a liability there
can be no levy, no notice of intent to levy,
nor any other collection actions.
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