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B. Post-assessment Payments Made by Petitioner
In 2000 and 2001, petitioner made a total of 4 payments in
the aggregate amount of $4,953.42 toward his unpaid liability for
1997.
In 2001, petitioner made a single payment in the amount of
$103 toward his unpaid liability for 1998.
As of April 20, 2001, the unpaid balance of petitioner’s
assessed liability was as follows:
Unpaid Balance
Year of Assessment
1997 $9,833.66
1998 15,768.19
25,601.85
C. Notice of Federal Tax Lien
On April 26, 2001, respondent filed a notice of Federal tax
lien with the County Clerk of Fort Bend County in Richmond,
Texas, in respect of petitioner’s outstanding tax liabilities for
1997 and 1998. Thereafter, on May 1, 2001, respondent sent
petitioner a Notice of Federal Tax Lien Filing and Your Right to
a Hearing Under IRC 6320, which petitioner received no later than
May 4, 2001.
D. Petitioner’s Request for a Hearing
On May 4, 2001, petitioner filed with respondent Form 12153,
Request for a Collection Due Process Hearing, in respect of his
tax liabilities for 1997 and 1998. In his request for a hearing,
petitioner stated that he did not agree with the filed notice of
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