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section 6654(a) addition to tax of $290.72. Petitioner received
the notice of deficiency, but he did not file a petition with
this Court. Respondent assessed the tax and additions to tax on
February 10, 2003. The assessment was reflected in a Form 4340,
Certificate of Assessments, Payments, and Other Specified Matters
(Form 4340), a copy of which was received by petitioner.
On October 1, 2003, respondent sent petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
(notice of levy). On October 9, 2003, respondent sent petitioner
a Notice of Federal Tax Lien Filing and Your Right to a Hearing
(notice of lien).
On October 30, 2003, petitioner timely requested a section
6330 hearing with respect to the notice of levy. On November 11,
2003, petitioner timely requested a section 6330 hearing with
respect to the notice of lien. At petitioner’s request, the
section 6330 hearing was conducted telephonically on February 26,
2004. Respondent refused to allow petitioner to record the
hearing.
A notice of determination was sent to petitioner on March
11, 2004. In the notice of determination, respondent: (1)
Rejected petitioner’s proposed collection alternative3 because
3 Petitioner stated that he would pay the tax immediately
and in full if respondent’s settlement officer could prove to him
that he was liable to pay tax. We hesitate to dignify this as a
collection alternative. However, respondent treated it as such,
(continued...)
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