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demonstrated that no genuine issue exists as to any material
fact, and a decision may be rendered as a matter of law. Rule
121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520
(1992), affd. 17 F.3d 965 (7th Cir. 1994).
We conclude that there is no genuine issue as to any
material fact and that a decision may be rendered as a matter of
law.
Background
On September 1, 2000, respondent filed a Notice of Federal
Tax Lien regarding petitioner’s income tax liabilities for 1989,
1990, 1991, 1992, 1993, and 1994 with the county auditor of
Pierce County, Tacoma, Washington (tax lien). The tax lien
listed the following amounts owed (as of August 27, 2000):
Tax Period Amount Owed
1989 $2,140.33
1990 1,947.40
1991 2,135.35
1992 1,830.55
1993 893.56
1994 2,036.89
On September 7, 2000, respondent issued to petitioner a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320 regarding his income tax liabilities for 1989,
1990, 1991, 1992, 1993, and 1994 (hearing notice).
On September 19, 2000, petitioner submitted a Form 12153,
Request for a Collection Due Process Hearing, regarding his 1989,
1990, 1991, 1992, 1993, and 1994 tax years (hearing request).
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