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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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Last modified: May 25, 2011