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payment of the liabilities specified and warned him of the
consequences of doing nothing.
Petitioner further argues that respondent was required to
send to him notice of intent to file the notice of tax lien
before the notice was actually filed, but petitioner is
incorrect. Section 6320 only requires that notice be sent to the
taxpayer within 5 days after the notice of tax lien has been
filed.
Petitioner argues that respondent violated some procedures
set forth in the Fair Debt Collection Practices Act (FDCPA),
Pub. L. 95-109, 91 Stat. 874 (1977), 15 U.S.C. sec. 1692 (2000).
By its terms, however, that act does not apply to employees of
the Government whose collection activities are part of their
jobs. See 15 U.S.C. sec. 1692a(6) (2000). Congress has amended
the Internal Revenue Code to require respondent to observe some
FDCPA procedures. See sec. 6304 as added by RRA 1998, sec. 3466,
112 Stat. 768; see also H. Conf. Rept. 105-599, at 291 (1998),
1998-3 C.B. 747, 1045. Petitioner’s reliance upon FDCPA
practices that Congress has not included in the Internal Revenue
Code is unavailing.
Nor has petitioner convinced us that respondent has deprived
him of constitutional due process by a perceived accumulation of
procedural mistakes. As we noted at trial, mistakes have been
made by both sides in this dispute. None of respondent’s
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