James L. Jensen - Page 8

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               On June 24, 2002, petitioner sent Ms. Chilton two letters in           
          response to the notice of determination.  In these letters,                 
          petitioner raised frivolous and groundless arguments.                       
               On July 1, 2002, petitioner filed an amended petition for              
          lien or levy action under section 6320(c) or 6330(d) seeking                
          review of respondent’s determination to proceed with collection             
          of petitioner’s 1994, 1995, 1996, and 1997 tax liabilities.                 
               On January 16, 2003, petitioner was served with the Court’s            
          notice setting case for trial and standing pretrial order setting           
          the case for trial during the Court’s 2-week session in                     
          Anchorage, Alaska, beginning on June 16, 2003.  The Court advised           
          petitioner that he needed to be ready and available during this             
          2-week period to try his case.                                              
               On April 22, 2003, petitioner filed a motion to dismiss                
          (motion to dismiss).  In the motion to dismiss, petitioner stated           
          that the parties were in negotiations to settle the case.                   
               On May 1, 2003, the Court ordered respondent to file a                 
          response to petitioner’s motion to dismiss on or before May 15,             
          2003.                                                                       
               On May 15, 2003, respondent filed a response to petitioner’s           
          motion to dismiss.  Respondent stated that he had made a diligent           
          inquiry and found that no negotiations were currently in progress           
          with petitioner.  Respondent further stated that he intended to             








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