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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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