- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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