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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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