Raymond Bourbeau - Page 6

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          6330(d) seeking review of respondent’s determination to proceed             
          with collection of petitioner’s 1996, 1997, and 1998 tax                    
          liabilities.                                                                
               On April 2, 2002, the Court ordered petitioner to file a               
          proper amended petition on or before April 30, 2002.  Attached to           
          the order were our Rules pertaining to lien and levy actions.               
               On May 6, 2002, petitioner filed an amended petition for               
          lien or levy action under Code section 6320(c) or 6330(d).                  
          Attached to the amended petition are, among other things, a                 
          transcript of the hearing and copies of petitioner’s transcripts            
          of account for the years in issue.                                          
               On February 21, 2003, respondent filed the motion for                  
          summary judgment.  Attached as exhibits to the motion for summary           
          judgment, among other things, are the transcript of the hearing             
          and transcripts of petitioner’s accounts for 1996, 1997, and                
          1998.                                                                       
               On February 24, 2003, the Court ordered petitioner to file a           
          response to respondent’s motion for summary judgment on or before           
          March 14, 2003.  Petitioner did not file a response to                      
          respondent’s motion for summary judgment.                                   
          Discussion                                                                  
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice (i.e., the             
          hearing notice) of the filing of a notice of lien under section             






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