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On January 16, 2003, a settlement officer with respondent's
Appeals Office (settlement officer) held one hearing with peti-
tioner that the settlement officer considered to be both an
Appeals Office hearing with respect to the notice of tax lien and
an equivalent hearing with respect to the notice of intent to
levy. During that hearing, the settlement officer relied on a
transcript of petitioner’s account with respect to each of his
taxable years 1991, 1994, 1996, 1998, and 1999.
On March 25, 2003, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 (notice of determination) in which that office
sustained the notice of tax lien. An attachment to the notice of
determination stated in pertinent part:
BRIEF BACKGROUND
The taxpayer filed voluntary income tax returns for
1991, 1994, 1996. The Collection Statute has since
expired on the 1991 tax liability. The taxpayer filed
frivolous returns for 1997, 1998 and 1999. Frivolous
return penalties were assessed for each of these three
years. The taxpayer has filed no income tax returns
since 1999 even though income information reported to
the Internal Revenue Service indicates that he would
have a filing requirement.
* * * * * * *
6(...continued)
tioner’s Form 12153 was timely filed with respect to the notice
of intent to levy.
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