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had no gross or taxable income (and consequently no tax
liability) for the applicable periods. Attached to the amended
returns was a three-page document in which petitioner stated that
although no section of the Internal Revenue Code establishes an
income tax liability, in order to avoid criminal prosecution for
failure to file a tax return, he was filing a tax return for 2000
and amended tax returns (with zeros reported for amounts on all
lines) for 1996-99 and reassessing his 1996-99 income as zero.
Petitioner requested a refund of all taxes paid for 1996-99 as
well as for 2000. The amended returns were not accepted by the
Internal Revenue Service (IRS), and by letter dated January 31,
2002, respondent informed petitioner that his request for a tax
refund was disallowed.
Petitioner received notice that Revenue Officer Charles Gear
had filed a notice of Federal tax lien with the Clerk of the
Circuit Court, Marion County, Florida. Subsequently, petitioner
submitted to respondent a Form 12153, Request for a Collection
Due Process Hearing, dated June 11, 2001, challenging the
appropriateness of the filing of the Federal tax lien.
By letter dated September 17, 2001, Appeals Officer Charles
R. Kelly informed petitioner that he was scheduling a telephone
hearing with petitioner for October 4, 2001, at 9:30 a.m.
Appeals Officer Kelly enclosed Forms 4340, Certificate of
Assessments, Payments, and Other Specific Matters, for 1996 and
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