Emil P. Tolotti, Jr. - Page 5

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          Lien.  The Notice of Federal Tax Lien states that petitioner has            
          an outstanding Federal income tax liability of $1,688.79 for the            
          taxable year 1995.  The signature block on the Notice of Federal            
          Tax Lien contains a facsimile signature.                                    
          On May 3, 2000, respondent mailed to petitioner a Notice of                 
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320.  On June 2, 2000, petitioner filed with respondent a                  
          Request for a Collection Due Process Hearing that included                  
          allegations challenging the existence and amount of petitioner’s            
          tax liability for 1995 on the ground that petitioner was not                
          informed of the statutory provisions imposing liability on him.             
          Petitioner also argued that the Notice of Federal Tax Lien Filing           
          was invalid because it did not include an original signature.               
               On July 10, 2000, Appeals Officer Donna Fisher conducted an            
          Appeals Office hearing in this matter that petitioner attended.             
          Prior to the hearing, Appeals Officer Fisher reviewed an                    
          individual master file transcript dated April 4, 2000, and a                
          computer transcript known as TXMODA dated June 30, 2000,                    
          regarding petitioner’s account for the 1995 taxable year.  The              
          transcripts indicated that respondent made assessments against              
          petitioner on October 19, 1998, for the tax, addition to tax, and           
          accuracy-related penalty set forth in the notice of deficiency              
          dated May 8, 1998, and for statutory interest.  In addition, the            
          transcripts indicated that on October 19 and November 9, 1998,              

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