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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Michigan.
Around March 1994, the Internal Revenue Service (IRS)
audited petitioner for 1990 and 1992. The audit resulted in
proposed increases in petitioner’s income tax liabilities for
those years. Petitioner knew that he could have appealed the
proposed increases, but instead he agreed to them.
On March 14, 2000, respondent mailed petitioner, via
certified mail, a Final Notice, Notice of Intent to Levy and
Notice of Your Right to a Hearing, with regard to his unpaid tax
liabilities for 1990 through 1998.
On or about April 10, 2000, respondent received from
petitioner a timely Request for a Collection Due Process Hearing,
Form 12153, (hearing request) with attachments. In the hearing
request, petitioner stated:
Petitioner admits that a certain obligation for taxes
due the Internal Revenue Service exists, but denies any
and all responsibility for said obligation for the
reason that a prior assignment of a lien and its
proceeds by Petitioner as grantor in favor of the
United States and the IRS as a grantee was extinguished
contrary to U.S. law through unlawful mortgage
foreclosure proceeding concluded on December 15, 1994.
Additionally, the mortgage foreclosed upon was a
forgery. It appears that the proceeds of these crimes
(proceeds which by prior tax liability are the
legitimate property of the United States), are
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