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Petitioner did not contest respondent’s deficiency
determination by filing a petition for redetermination with this
Court. Accordingly, on July 24, 2000, respondent assessed the
determined deficiency and accuracy-related penalty, as well as
statutory interest. On that same day, respondent sent petitioner
a notice of balance due, informing him that he had a liability
for 1998 and requesting that he pay it. Petitioner failed to pay
the amount owing. About a month later, on August 28, 2000,
respondent sent petitioner a second notice of balance due.
Again, petitioner failed to pay the amount owing.
C. Respondent’s Lien Notice and Petitioner’s Response
On October 25, 2001, respondent filed a notice of Federal
tax lien with the County Recorder of Clark County (Las Vegas),
Nevada. Respondent filed the notice in respect of petitioner’s
income tax liability for 1998, the unpaid assessed balance of
which was $5,225.10 at the time that the notice was filed.2
On October 30, 2001, respondent mailed to petitioner at his
Las Vegas address a Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under IRC 6320 in respect of his outstanding
tax liability.
2 Respondent also filed the notice of Federal tax lien in
respect of petitioner’s outstanding liability for civil penalties
under sec. 6702 (relating to frivolous income tax returns) for
1998 and 1999. Petitioner’s liability for those penalties is not
before us in the instant case. See Van Es v. Commissioner, 115
T.C. 324 (2000).
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