Harold E. Call - Page 7

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                    And so their motion for summary judgment was                      
               denied.  At this trial today, there is a verbatim                      
               record being made, and if you have any other issues                    
               that you wish to raise other than those that were in                   
               your previous documents, this is your chance to raise                  
               them.                                                                  
                    If you don’t raise what I deem to be a legitimate                 
               issue under Section 6330(c)(2), which I have                           
               jurisdiction to consider, and I rule against you, then                 
               other than your right to appeal to a Circuit Court of                  
               Appeals, your case will be over.                                       
                    So if you have any other additional issues that                   
               you wanted to raise or discuss with the Appeals                        
               Officer, you need to raise them here today so that I                   
               can determine if this case should be remanded to                       
               appeals to consider those issues, or if there is not                   
               reason to remand the case because there is [sic] no                    
               issues that I can’t adequately dispose of here at this                 
               trial.  All right?                                                     
               The sole new issue specifically raised by petitioner at                
          trial was that the filing of the notice of tax lien was invalid             
          because he did not receive proper notification of this action               
          from respondent.  Petitioner testified that he instead learned of           
          the filing from a credit watch service to which he subscribes and           
          which alerts him of adverse activity concerning his credit                  
          report.                                                                     
               The parties subsequently filed posttrial briefs.  Petitioner           
          recapitulated the position taken throughout these proceedings and           
          at trial, focusing once again on lack of a recorded hearing and             
          of sufficient notification, verification, and documentation of              
          procedural requisites.                                                      







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Last modified: May 25, 2011