Robert R. Villwock - Page 6

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               Petitioner knew that he had the right to contest                       
          respondent’s deficiency determination by filing a petition for              
          redetermination with this Court.2  However, petitioner chose not            
          to do so.  Accordingly, on March 6, 2000, respondent assessed the           
          determined deficiency and accuracy-related penalty, as well as              
          statutory interest.  On that same day, respondent sent petitioner           
          a notice titled “WE CHANGED YOUR ACCOUNT”, informing him that he            
          had a liability for 1997 and requesting that he pay it.  By                 
          letter dated March 20, 2000, petitioner acknowledged receipt of             
          this notice but failed to pay the amount owing.                             
               On April 10, 2000, respondent sent petitioner a second                 
          notice of balance due for 1997.  Petitioner failed to pay the               
          amount owing.                                                               
               C.  Respondent’s Final Notice and Petitioner’s Response                
               On August 3, 2000, respondent mailed to petitioner a Final             
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing in respect of his outstanding tax liability for 1997.               
               On August 18, 2000, petitioner filed with respondent a Form            
          12153, Request for a Collection Due Process Hearing.  Petitioner            
          requested verification from the Secretary that all applicable               

               2  In this regard, petitioner’s letter dated Dec. 27, 1999,            
          stated in pertinent part as follows:  “The notice also tells me             
          that if I want to ‘contest this deficiency in court before making           
          any payment’, that I must ‘file a petition with the United States           
          Tax Court’.”                                                                

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