Michael Norton - Page 4

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          In 2001, respondent assessed the tax, penalty, and interest for             
          1995.  During 2001, petitioner’s tax deficiency for 1995 of                 
          $440,042 was paid out of the seized funds.                                  
               On June 28, 2001, respondent filed a notice of Federal tax             
          lien regarding petitioner’s 1995 tax year (notice of lien).  That           
          same day, respondent sent petitioner a copy of the notice of                
               On July 25, 2001, petitioner timely filed a Form 12153,                
          Request for a Collection Due Process Hearing, regarding his 1995            
          tax year.  In the hearing request, petitioner stated:  “I believe           
          these taxes were paid from the monies seized by U.S. Customs.”              
               On November 8, 2001, respondent mailed petitioner a letter             
          identifying Appeals Officer Fernando Orozco as assigned to                  
          consider the collection action and to conduct petitioner’s                  
               Petitioner had a correspondence hearing with Appeals.  On              
          November 25, 2001, petitioner wrote Appeals Officer Orozco a                
          letter setting forth petitioner’s position regarding his case.              
          Petitioner claimed that his total tax liability for 1995,                   
          including penalties and interest, had been paid.                            
               On November 29, 2001, Appeals Officer Orozco prepared an               
          Appeals transmittal and case memorandum.  Appeals Officer Orozco            
          noted that petitioner was convicted of tax evasion, and that the            
          Internal Revenue Service (IRS) had received a payment of                    

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