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amounts that could not be computed at the time of the
determination. Petitioner did not file a petition with this
Court.
Petitioner stamped the notice of deficiency “Refused for
Fraud F.R.C.P. 9(b)” and returned it to respondent with an
attachment in which petitioner alleged: (1) The notice of
deficiency was fraudulent; (2) he did not receive notice of the
examination; (3) he is not liable for tax; and (4) respondent
failed to prepare proper substitutes for returns.
D. Notice of Federal Tax Lien
On January 22, 2003, respondent filed a notice of Federal
tax lien relating to petitioner’s unpaid income tax liabilities
of $14,777.63 for 1994, $9,035.91 for 1995, $9,316.57 for 1996,
$11,563.38 for 1997, $7,871.54 for 1998, and $13,809.37 for 1999.
On January 27, 2003, respondent sent petitioner a notice that the
notice of Federal tax lien for 1994-99 had been filed.
Petitioner timely requested a hearing under sections 6320
and 6330 on February 25, 2003. In the hearing request,
petitioner claimed that he was not a “taxpayer” as defined in the
Internal Revenue Code or by any regulation thereunder, and he
asked: (1) What, if any Federal tax liability does he have? (2)
for which Federal tax is he liable? (3) what action made him
liable for Federal tax? (4) why was he not told that he owed
Federal tax? and (5) who assessed the Federal tax?
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