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more intrusive than necessary. The file indicates that
the legal requirements pursuant to filing a lien were
met and that there was no improper action in such
filing. You had no challenge to the appropriateness of
the collection action, except your assertion that you
do not owe the tax. Since the Tax Court and Appeals
have previously determined that the tax is owed, the
filing of the notice of Federal tax lien is appropriate
to protect the Government’s interest.
OPINION
As we understand petitioner’s position, he is challenging
the respective underlying tax liabilities for his taxable years
1993, 1994, and 1995.1 With respect to petitioner’s taxable
years 1993 and 1994, petitioner received a notice of deficiency,
filed a petition with respect to that notice, thereby commencing
the case at docket No. 2446-98, and did not appear at the trial
in that case which the Court had set for trial on April 12, 1999,
in Washington, D.C. As a consequence, the Court granted respon-
dent’s oral motion to dismiss for lack of prosecution in the case
at docket No. 2446-98 and entered an Order of Dismissal and
Decision against petitioner in that case. Thereafter, the Court
denied petitioner’s motion to vacate that Order. With respect to
petitioner’s taxable year 1995, petitioner received a notice of
1Specifically, petitioner argues that he has shown in an-
other case that he commenced in the Court with respect to his
taxable year 1996 that he is not liable for tax not only for that
year, but also for 1993, 1994, and 1995. We note that after the
trial in the instant case the Court issued an Opinion with
respect to petitioner’s taxable year 1996 in the other case on
which petitioner is relying, in which we sustained respondent’s
determinations with respect to that year. See Jombo v. Commis-
sioner, T.C. Memo. 2002-273.
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