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and argument. Respondent contends and we agree that this Court’s
review in this case is limited to the question of whether
respondent abused his discretion in determining to proceed with
collection of petitioner’s 1995 and 1996 income tax liabilities.
Petitioner argues that he has been denied due process and that
his rights have been violated in prior proceedings before this
and other courts.
FINDINGS OF FACT
Petitioner’s 1995 and 1996 tax years were before this Court
(designated docket No. 9029-99), and after a trial on the merits,
a bench opinion was rendered on April 7, 2000. The bench opinion
addressed whether petitioner and his wife were entitled to claim
itemized deductions on Schedule A, Itemized Deductions, of their
return regarding petitioner’s employment and other miscellaneous
items. Respondent, in accord with the decision entered pursuant
to the holding in the bench opinion, assessed income tax of
$4,186 and $2,557 for petitioner’s 1995 and 1996 tax years,
respectively. Petitioner appealed to the Court of Appeals for
the Ninth Circuit and, on April 18, 2001, this Court’s decision
was affirmed in an unpublished opinion. Orr v. Commissioner, 87
AFTR 2d 2001-832 (9th Cir. 2001).
On February 9, 2001, respondent issued a Form 1058, Final
Notice of Intent to Levy and Notice of Your Right to a Hearing,
to petitioner, and on March 9, 2001, petitioner submitted a Form
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