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stating that the Appeals Office had assigned petitioner’s 1996
tax return to the Examination Division. The letter requested
that petitioner provide certain documents and invoices to
substantiate the adjustments made to his 1996 tax return. The
letter further requested that petitioner bring the requested
items to an appointment scheduled for August 9, 2001.
On August 17, 2001, petitioner met with the examiner to
discuss his 1996 liability during the audit reconsideration.
Petitioner failed to bring any documentation to substantiate his
entitlement to the deductions, dependency exemptions, filing
status, and child care credit disallowed in the notice of
deficiency.
On January 8, 2002, respondent mailed to petitioner the
notice of determination at issue here. Respondent determined
that all legal and administrative procedures were met, that
petitioner failed to present any collection alternatives, and
that the proposed lien was appropriate. Petitioner had an
opportunity for audit reconsideration but failed to provide any
evidence other than his own oral testimony.
Section 7491 is not applicable in this case because
examination of petitioner’s 1996 tax return commenced prior to
July 22, 1998, the effective date of section 7491. The burden of
proof is on petitioner. Rule 142(a).
Section 6321 imposes a lien in favor of the United States on
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