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hearing on respondent’s motion would not materially assist in our
determination of this matter. For reasons stated below, we will
grant respondent’s motion for summary judgment.
Background
The record establishes or the parties do not dispute the
following.
When he filed his petition, petitioner resided in Boston,
Massachusetts.
Petitioner filed an untimely Federal income tax return for
1996 and failed to fully pay the income tax liability reported on
the return. On October 9, 2003, respondent issued petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing (final levy notice) with respect to his unpaid 1996
Federal income tax liability. On October 10, 2003, respondent
issued petitioner a Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under IRC 6320 (final lien notice) with
respect to his unpaid 1996 income tax liability.
Petitioner timely filed separate Forms 12153, Request for a
Collection Due Process Hearing, with respect to the final levy
notice and the final lien notice. These Forms 12153 stated
identically:
The taxpayer is requesting a due process hearing
as the Service is by threatening enforcement actions is
[sic] acting in a manner which is contrary to the best
interest of the government and the taxpayer.
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