Donald A. Ramirez - Page 4

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          request.  Petitioner did not respond.  Ms. Melick sent a second              
          letter on October 8, 2003, requesting that petitioner respond                
          within 15 days.  Petitioner did not respond.                                 
               Respondent conducted an administrative review of                        
          petitioner’s file.  On November 25, 2003, respondent sent                    
          petitioner notice of determination sustaining the filing of the              
          Federal tax lien for 1998.                                                   
               On December 23, 2003, petitioner timely filed a petition                
          with the Court.  Upon order of the Court, petitioner filed an                
          amended petition on February 24, 2004, seeking review of the                 
          underlying tax liability and relief from the lien collection                 
          action under section 6320.                                                   
               The parties have stipulated that, subsequent to petitioner’s            
          filing with this Court, an installment agreement has been entered            
          into for petitioner’s outstanding tax liability, and that any                
          overpayments resulting from the allowance of petitioner’s                    
          schedule A expense deduction for 1996 will be applied to the                 
          outstanding tax liability for 1998.                                          
               At trial, petitioner raised a reasonable cause defense to               
          the section 6651 additions to tax, citing his 1996 surgery.                  
                                       OPINION                                         
               Pursuant to section 6330(d)(1), within 30 days of the                   
          issuance of the notice of determination, the taxpayer may appeal             
          the determination to this Court if we have jurisdiction over the             






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