Gerald H. Klawonn - Page 3

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          B.   The Section 6320(b) Hearing and Respondent’s Notice of                 
               On March 28, 2001, respondent’s Appeals Office conducted a             
          hearing under section 6320(b) in petitioner’s case relating to              
          assessments of his income tax liabilities for tax years 1986,               
          1988, 1989, 1995, 1996, and 1998.  Petitioner attended the                  
          hearing.  At the hearing, petitioner questioned whether an                  
          Assessment officer had signed the assessment documents for the              
          years in issue.  The Appeals officer gave petitioner a copy of a            
          Form 4340, Certificate of Assessments and Payments, for each of             
          the years in issue.  Petitioner did not challenge the                       
          appropriateness of the intended method of collection.                       
               On May 17, 2001, respondent sent petitioner a Notice of                
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (the determination letter), in which respondent                 
          stated that collection from petitioner of his tax liability for             
          tax years 1986, 1988, 1989, 1995, 1996, and 1998 would proceed.             
          On June 20, 2001, petitioner filed a petition for lien or levy              
          action under section 6320(c) or section 6330(d).                            
          A.   Summary Judgment                                                       
               We may grant summary judgment if there is no genuine issue             
          of material fact and a decision may be rendered as a matter of              
          law.  Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518,           
          520 (1992), affd. 17 F.3d 965 (7th Cir. 1994); Zaentz v.                    

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