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Year Assessment Date
1994 Oct. 18, 1999
1995 Dec. 27, 1999
1996 Aug. 28, 2000
1997 Sept. 4, 2000
Respondent sent petitioner notices and demand for payment of
the assessments as follows: In October 1999 for 1994, in
December 1999 and February 2000 for 1995, in August and September
2000 for 1996, and in September 2000 for 1997. Petitioner
responded to the requests for payment for 1994 and 1997 with
several 15-page letters containing frivolous and groundless
arguments.
On or about December 28, 2000, respondent filed a notice of
Federal tax lien regarding petitioner’s income tax liabilities
for 1994, 1995, 1996, and 1997 with the Recording District of
Cordova, Anchorage, Alaska (tax lien). The tax lien listed
$9,523.39 owed for 1994, $164,595.94 owed for 1995, $13,249.99
owed for 1996, and $13,659.98 owed for 1997.
On January 3, 2001, respondent issued to petitioner a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 regarding his income tax liabilities for 1994, 1995, 1996,
and 1997 (hearing notice). Attached to the hearing notice was a
copy of the tax lien.
On January 31, 2001, in response to the hearing notice,
petitioner submitted a 15-page letter containing frivolous and
groundless arguments. Petitioner did not file a Form 12153,
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Last modified: May 25, 2011