Larry R. Johnston - Page 3

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          Internal Revenue Service (IRS) “to circumvent taxpayers’ rights             
          by prompting them to petition the U.S. Tax Court”.2  Petitioner             
          at no time petitioned this Court for redetermination of the                 
          amounts reflected in the notices.  Respondent assessed the tax,             
          additions to tax, and interest amounts due for each year on                 
          February 12, 2001.  These assessments for the 5 years in issue              
          totaled $1,472,914.84.  Respondent also sent notices of balance             
          due with respect to each year on February 12 and March 19, 2001.            
               On January 11, 2002, respondent issued to petitioner a Final           
          Notice - Final Notice of Intent To Levy and Notice of Your Right            
          To a Hearing with respect to his unpaid income tax liabilities              
          for 1993 through 1997.  Respondent then on February 5, 2002,                
          issued to petitioner a Notice of Federal Tax Lien Filing and Your           
          Right to a Hearing Under IRC 6320.  A Form 12153, Request for a             
          Collection Due Process Hearing, signed by petitioner on March 10,           
          2002, was apparently received by the IRS on March 12, 2002.                 
          Petitioner checked boxes on the Form 12153 indicating                       
          disagreement with both a “Filed Notice of Federal Tax Lien” and a           
          “Notice of Levy/Seizure”.  He also apparently attached a                    

               2 Neither the letter sent by petitioner in response to the             
          notices of deficiency nor the attachment to his Form 12153,                 
          Request for a Collection Due Process Hearing, has been made a               
          part of the record in this case.  Information regarding the                 
          existence and contents of these documents is derived from                   
          excerpts quoted in the Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330.  Petitioner            
          has not alleged that the notice of determination is in any way              
          inaccurate in its recitation of such background information.                





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