Greg A. Bell - Page 2

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               Greg A. Bell, pro se.                                                  
               Stephen J. Neubeck, for respondent.                                    


                                       OPINION                                        
               FOLEY, Judge:  The issue for decision is whether respondent            
          abused his discretion when he precluded petitioner, at the 2005             
          hearing, from challenging petitioner’s underlying tax liability             
          and sustained the Notice of Federal Tax Lien relating to                    
          petitioner’s 1997 liability.                                                
                                     Background                                       
               Petitioner failed to file his 1997 Federal income tax                  
          return.  By notice dated September 15, 2000, respondent                     
          determined a deficiency in, and additions to, petitioner’s 1997             
          Federal income tax.  Respondent mailed such notice to petitioner,           
          but petitioner did not receive it.                                          
               On April 27, 2002, a Notice of Intent to Levy and Notice of            
          Your Right to a Hearing relating to 1997 was mailed to                      
          petitioner.  On May 22, 2002, petitioner timely filed a Form                
          12153, Request for a Collection Due Process Hearing (2002                   
          request).  In the 2002 request, petitioner contended that he “was           
          never provided proof of the amount allegedly owed, neither in               
          direct documentation, nor statements of how rules/laws and                  
          calculations were applied.”  The Appeals officer scheduled a                
          hearing for October 5, 2002 (2002 hearing).  In a letter dated              






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