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filing of a tax lien relating to petitioner’s 1998 tax liability
was appropriate.1
The sole issue for decision is whether respondent’s
determination that the filing of a tax lien relating to
petitioner’s 1998 tax liability was appropriate was an abuse of
discretion. We hold that it was not.
FINDINGS OF FACT
A. Petitioner and His 1998 Income Tax Return
Petitioner resided in Houston, Texas, when he filed the
petition in this case.
Petitioner reported on his 1998 income tax return that he
had no wages, other income, or tax liability, and that he had
taxes withheld of $2,935.30. He claimed a refund of $2,935.30.
Petitioner attached a letter to his 1998 return in which he
contended that: Wages are not income; petitioner is not required
by law to file a return or pay income tax; and respondent failed
to provide petitioner with a copy of the law requiring him to pay
income tax.
B. Notice of Deficiency and Bankruptcy
On September 8, 1999, respondent sent a notice of deficiency
for 1998 to petitioner at the address shown on petitioner’s 1998
return. In it, respondent determined a deficiency in
1 Unless otherwise indicated, section references are to the
Internal Revenue Code as amended.
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