Harvey Doyne Perry, Jr. - Page 7

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          to do so.  Accordingly, on August 14, 2000, respondent assessed             
          the determined deficiency and accuracy-related penalty, as well             
          as statutory interest.  On that same day, respondent sent                   
          petitioner and his wife a notice of balance due, informing them             
          that they had a liability for 1997 and requesting that they pay             
          it.  Petitioner and his wife failed to pay the amount owing.                
               Respondent sent petitioner and his wife a second notice of             
          balance due for 1997.  Again, they failed to pay the amount                 
               C.  Respondent’s Final Notice and Petitioner’s Response                
               On February 8, 2001, respondent mailed to petitioner and his           
          wife a Final Notice--Notice of Intent to Levy and Notice of Your            
          Right to a Hearing in respect of their outstanding tax liability            
          for 1997.                                                                   
               On March 11, 2001, petitioner filed with respondent Form               
          12153, Request for a Collection Due Process Hearing.5  The                  
          request, which was accompanied by a cover letter dated March 6,             
          2001, included, inter alia, a challenge to the existence of the             

               According to your “Deficiency Notice”, listed above,                   
               there is an alleged deficiency with respect to my 1997                 
               income tax of $32,564.00 * * *, and if I wanted to                     
               “contest this deficiency before making payment, “I                     
               must” [sic] file a petition with the United States Tax                 
               5  The request was not executed by petitioner’s wife, nor              
          did it purport to be filed on her behalf.                                   

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