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On May 24, 1995, respondent sent a notice of deficiency for
the 1992 taxable year to petitioner at the Florida address,
determining a deficiency of $1,294 and an addition to tax under
section 6651(a) of $323.
On August 9, 1995, respondent sent a notice of deficiency
for the 1993 taxable year to petitioner at the Florida address
determining a deficiency of $3,135 and additions to tax under
sections 6651(a) and 6654(a) of $783 and $131, respectively.
Apparently, petitioner did not receive the aforesaid notices
of deficiency. Respondent conceded this and stated that this was
because petitioner had moved to New York in 1991 and the Internal
Revenue Service had no notice as to his new address.
On September 25, 1999, respondent sent a letter to
petitioner at his Palo Alto, California, address which provided a
summary of the assessed taxes and additions to tax for each of
the taxable years at issue.
On October 20, 2000, respondent sent petitioner a Letter
3172, Notice of Federal Tax Lien Filing And Your Right To A
Hearing. Petitioner filed a Form 12153, Request for a Collection
Due Process Hearing with respondent on November 2, 2000.
Petitioner stated that he had not been contacted by respondent
prior to October 1999, that he had responded to all calls and
letters since that date, and that he was “never given a chance to
appear at an office”. Petitioner did not dispute the amount of
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