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petitioner’s accounts for 1996, 1997, and 1998.
On November 8, 2002, the Court ordered petitioner to file a
response to respondent’s motion for summary judgment on or before
December 9, 2002. 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
6323. Section 6320 further provides that the taxpayer may
request administrative review of the matter (in the form of a
hearing) within a prescribed 30-day period. The hearing
generally shall be conducted consistent with the procedures set
forth in section 6330(c), (d), and (e). Sec. 6320(c).
The petition in this case is a 16-page document filled with
frivolous, tax-protester arguments. Petitioner appears to
challenge the underlying liability. Petitioner received
statutory notices of deficiency for each of the years in issue
and did not file a petition for redetermination. Accordingly,
petitioner cannot contest the underlying deficiencies for 1996,
1997, and 1998. Sec. 6330(c)(2)(B); Sego v. Commissioner, 114
T.C. 604, 610-611 (2000); Goza v. Commissioner, 114 T.C. 176,
182-183 (2000).
Where the validity of the underlying tax liability is not
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