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and (4) he never received a valid notice of deficiency or a
demand for payment of any of the liabilities.
On June 24, 2004, petitioner went to Parker’s office with a
court reporter. Parker told petitioner that he could not have a
face-to-face hearing because the arguments that he had raised
were frivolous. On July 8, 2004, petitioner wrote to Parker
arguing that payment of taxes is voluntary and that there was no
valid assessment of tax against him.
On August 6, 2004, respondent sent petitioner (1) a Notice
of Determination Concerning Collection Action Under Section 6320
(notice of determination) regarding frivolous return penalties
that respondent had assessed for petitioner’s 1995-2000 tax
years; and (2) a Decision Letter Concerning Equivalent Hearing
Under Section 6320 (decision letter) stating that respondent had
concluded that imposition of the tax lien regarding petitioner’s
income tax liabilities for 1995-96 was appropriate. If
respondent had realized petitioner’s request for a hearing with
respect to his income tax liability for 1995-96 was timely,
respondent would have issued a notice of determination instead of
a decision letter. See secs. 6320(c), 6330(c)(3), (d).
Petitioner filed a petition with the Court challenging the
notice of determination and the decision letter.1 By order dated
1 By order dated Sept. 21, 2005, the Court denied
respondent’s motion to dismiss for lack of jurisdiction on the
(continued...)
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