John J. Green - Page 4

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               The point is that the only assessment that can be made is              
               off of a return and the return that I gave you had zeros on            
               it.                                                                    
          At the hearing, the settlement officer gave petitioner a literal            
          transcript of assessments and notices.  On October 5, 2001, a               
          Form 4340, Certificate of Assessments, Payments, and Other                  
          Specified Matters, was mailed to petitioner.                                
               On November 1, 2001, respondent issued a Notice of                     
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 which stated:                                                   
               A review of the case history indicates a valid assessment              
               was made, notice and demand was provided and a neglect or              
               refusal to pay occurred.  In December of 1999 the taxpayer             
               responded to a request for payment of the subject assessment           
               with a letter questioning the governments’ [sic] authority             
               to assess and collect tax.  The Federal Tax Lien was filed             
               in accordance with established procedures.                             
               The Federal Tax Lien is sustained.  Proper administrative              
               procedures were followed by Service personnel.  This                   
               recommendation balances the need for efficient tax                     
               administration.  Mr. Green has not proposed alternatives to            
               the lien.                                                              
               On November 30, 2001, petitioner filed a petition with the             
          Court in which he contended:  (1) There was “no valid assessment”           
          of taxes; (2) he did not receive the “statutory Notice and Demand           
          for payment” of the taxes at issue; (3) he did not receive a                
          valid notice of deficiency; and (4) he had no underlying tax                
          liability.  In the petition, petitioner argued that he did not              
          receive the following documents at the hearing:  (1) Verification           







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