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F. Respondent’s Notice of Determination
On August 9, 2001, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 with regard to his tax
liabilities for 1997 and 1998. In the notice, the Appeals Office
concluded:
the Notice of Filing of a Federal Tax Lien was legally
and procedurally correct. There exists no basis for
withdrawal of the Notice.
G. Petitioner’s Petition
On September 13, 2001, petitioner filed with the Court a
Petition for Lien or Levy Action seeking review of respondent’s
notice of determination.3 In the petition, there are no
assignments of error or allegations of fact other than the terse
statement that petitioner disagrees with “Penalties + Interest”.
H. Respondent’s Motion For Summary Judgment
As stated, respondent filed a Motion For Summary Judgment.
Respondent contends that the petition contains nothing other than
a challenge to the underlying liability (for interest and
additions to tax), but that petitioner is precluded from pursuing
such a challenge because he failed to raise that issue in the
administrative hearing before the Appeals officer.
3 At the time that the petition was filed, petitioner
resided in Houston, Texas.
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Last modified: May 25, 2011