Robert Lee, Jr. - Page 3

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          September 9, 2002, respondent issued to petitioner a notice of              
          balance due for the taxable year 1995.                                      
               On January 21, 2003, respondent mailed to petitioner a Final           
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          requesting that petitioner pay his outstanding tax liability for            
          1995.  On February 12, 2003, petitioner submitted to respondent a           
          Request for Collection Due Process Hearing challenging the                  
          validity of the assessment for 1995.  Specifically, petitioner              
          argued that respondent failed to provide petitioner with either a           
          record of the assessment or a notice of the assessment.                     
               On July 22, 2003, the parties met for the purpose of                   
          conducting an administrative hearing regarding respondent’s                 
          proposed levy.  However, the hearing was terminated when the                
          Appeals officer informed petitioner that he would not be                    
          permitted to make an audio recording of the hearing.                        
               On July 31, 2003, respondent mailed to petitioner a Notice             
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330.  In the notice, respondent determined that it             
          was appropriate to proceed with the proposed levy because:  (1)             
          Petitioner had previously challenged respondent’s notice of                 
          deficiency for 1995 in the Tax Court, and, therefore, he was                
          barred from challenging his underlying tax liability pursuant to            
          section 6330(c)(2)(B); (2) petitioner failed to file Federal                
          income tax returns from 1995 to 2002, and, therefore, he was not            

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