Christopher Kiley - Page 16

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          liabilities for 1995, 1997, and 1998.  In the notice, the Appeals           
          Office concluded that respondent’s determination to proceed with            
          collection by way of levy should be sustained.                              
               G.  Petitioner’s Petition and Amended Petition                         
               On March 25, 2002, petitioner filed with the Court a                   
          Petition for Lien or Levy Action seeking review of respondent’s             
          notice of determination.9  Thereafter, on June 19, 2002,  an                
          Amended Petition for Lien or Levy Action was filed.                         
               In the amended petition, petitioner challenges “the                    
          appropriateness of (the) collection action” and “the existence of           
          the underlying liability”.  Petitioner also alleges: (1) The                
          Appeals officer failed to obtain verification from the Secretary            
          that the requirements of applicable law or administrative                   
          procedure were met as required under section 6330(c)(1); (2)                
          petitioner never received notice and demand for payment for the             
          liabilities in issue; and (3) no “valid” assessment was ever                
          made.  Finally, petitioner alleges that he never received a                 
          “valid notice of deficiency” for any of the years in issue.  The            
          amended petition contains no facts in support of any of the                 
          foregoing allegations.                                                      
               H.  Respondent’s Motion For Summary Judgment                           
               As stated, respondent filed a Motion For Summary Judgment              

               9  At the time that the petition was filed, petitioner                 
          resided in Pahrump, Nevada.                                                 

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