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560 (2000). Petitioner has not filed a response to respondent’s
motion as required by our order of October 2, 2002.
Petitioner filed Federal income tax returns for 1994, 1997,
1998, and 1999. Those returns reported taxes due; however,
petitioner did not pay the entire amount of the taxes shown on
his returns. Respondent assessed the taxes reported and also
assessed additions to tax and interest.
On April 4, 2001, respondent issued to petitioner a “Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320”.2 The lien filing was made with respect to unpaid taxes
stated as follows:
Type of tax Period Amount
1040 12/31/1994 $698.69
1040 12/31/1997 189.34
1040 12/31/1998 3,450.59
1040 12/31/1999 1,466.73
Petitioner filed a Form 12153, Request for a Collection Due
Process Hearing, with respect to the lien filing. An attachment
to that Form 12153 states in pertinent part:
Summarizing, I am requesting a “Due Process
Hearing” as outlined Form 12153. [sic] I am
“challenging the appropriateness of (the) collection
action” as specified in 6330(c)(2)(A)(ii) since the IRS
denied all of my requests of the initial “examinations”
and “interviews” as provided in Publications 1 & 5. In
addition, no lien for taxes pursuant to Code Sections
6321 and 6322 is possible because no valid, underlying
2Respondent filed a Form 668(Y)(c), Notice of Federal Tax
Lien, with the prothonotary of Lackawanna County, Scranton,
Pennsylvania.
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