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respondent issued to petitioner a notice and demand for payment
of the assessed amounts.
During the Appeals Office hearing, petitioner requested that
the Appeals officer identify the statutory provisions
establishing petitioner’s liability for Federal income tax.
Petitioner was informed that although he would be permitted to
raise any valid challenge he might have to the specific amounts
of income that were reported to respondent by third-party payors,
he would not be permitted to raise constitutional challenges to
his underlying tax liability for 1995. The Appeals officer
terminated the hearing after petitioner declined to discuss
alternatives to collection.
On February 16, 2001, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 stating that respondent’s determination
(that the filing of the Notice of Federal Tax Lien for
liabilities owing for the taxable year 1995 is appropriate)
should be sustained. On March 2, 2001, petitioner filed with the
Court an imperfect Petition for Lien or Levy Action seeking
review of respondent’s notice of determination.3 On April 6,
2001, petitioner filed an amended petition including the
following allegations: (1) The Notice of Federal Tax Lien was not
3 At the time that the petition was filed, petitioner
resided in Reno, Nevada.
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