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(2000), and Moore v. Commissioner, 114 T.C. 171, 175 (2000).
Thus, we lack jurisdiction to review respondent’s determination
relating to the penalties under section 6682 for 2002 and section
6702 for 1997-2001, and we dismiss for lack of jurisdiction the
portion of this case that pertains to those penalties.
B. Whether Respondent’s Determination Relating to the Lien
Imposed on Petitioner for 1998, 2001, and 2002 Was Correct
Petitioner contends that respondent’s determination relating
to the lien imposed on petitioner for 1998, 2001, and 2002 was
incorrect because: (1) Respondent did not give him a copy of
Form 23C; (2) there was no valid assessment of tax for 1998,
2001, and 2002; (3) he did not receive a notice and demand for
payment for 1998, 2001, and 2002; (4) respondent did not produce
verification from the Secretary that requirements of applicable
law and administrative procedures have been met or that
respondent’s employees had authority from the Secretary to
collect tax from petitioner; (5) he is not liable for the tax for
1998, 2001, and 2002 that respondent contends he owes; and (6)
respondent improperly failed to give petitioner the opportunity
to have a face-to-face hearing. We disagree. Petitioner’s
contentions are frivolous for reasons stated next.
1. Whether Respondent Was Required To Provide Form 23C for
1998, 2001, and 2002
Section 6330(c)(1) requires the Appeals officer to verify
that the requirements of any applicable law or administrative
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