Michael Norton - Page 5

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          $440,041.85 for petitioner’s tax deficiency for 1995.  Appeals              
          Officer Orozco stated that there was no agreement to pay off, or            
          write off, petitioner’s penalty or interest for 1995.   Appeals             
          Officer Orozco noted that all required procedures and applicable            
          law had been followed and petitioner offered no collection                  
               On November 30, 2001, respondent issued a Notice of                    
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 to petitioner regarding his 1995 tax year (notice of            
          determination).  In the notice of determination, respondent                 
          determined that the filing of the notice of lien was appropriate,           
          that the assessed interest and penalties were due and owing yet             
          remained unpaid, and that petitioner had not offered an                     
          alternative to enforced collection action.  The attachment to the           
          notice of determination stated that petitioner argued solely that           
          the entire tax liability had been paid from the seized funds, and           
          noted that the IRS received funds to pay only the tax deficiency            
          and the current amount owed was for the fraud penalty and                   
               Section 6320 provides that the Secretary will furnish the              
          person described in section 6321 with written notice (i.e., the             
          hearing notice) of the filing of a notice of lien under section             
          6323.  Section 6320 further provides that the taxpayer may                  

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