Scott Alan Brandenburg - Page 4

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          respondent filed a notice of Federal tax lien in Dade County,               
          Florida, with respect to petitioner’s 1995-96 income taxes.                 
               On January 11, 2002, petitioner submitted to respondent six            
          Forms 1040EZ, Income Tax Return for Single and Joint Filers With            
          No Dependents, for 1995-2000.  Petitioner entered zeros for his             
          income and on the lines for total tax.  Respondent assessed                 
          frivolous return penalties under section 6702 for those returns.            
               Petitioner filed claims for refund for 1995 and 1996 early             
          in 2002.  Respondent rejected those claims on March 13, 2003.               
          Petitioner filed his 2002 return on October 8, 2003.                        
               On January 16, 2004, respondent filed a notice of Federal              
          tax lien in Alachua County, Florida, with respect to petitioner’s           
          income tax liabilities for 1995-96 and frivolous return penalties           
          under section 6702 for 1995-2000.  On January 20, 2004,                     
          respondent sent petitioner a Notice of Federal Tax Lien Filing              
          and Your Right to a Hearing Under IRC � 6320 relating to                    
          petitioner’s income tax liabilities for 1995-96 and frivolous               
          return penalties for 1995-2000 (the January 2004 lien notice).              
               On February 18, 2004, petitioner submitted to respondent an            
          unsigned Form 12153, Request for a Collection Due Process                   
          Hearing.  Respondent returned it to petitioner and asked that he            
          sign and return it to respondent.  Petitioner did so.                       
               On May 13, 2004, respondent’s Office of Appeals sent                   
          petitioner a letter:  (1) Explaining the hearing process under              






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