Greg A. Bell - Page 3

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          August 30, 2002, the Appeals officer informed petitioner that the           
          underlying tax liability could not be challenged at the 2002                
          hearing because petitioner had a prior opportunity to dispute the           
          liability.  In a letter dated September 5, 2002, the Appeals                
          officer enclosed a copy of the notice of deficiency and                     
          reiterated that petitioner could not, at the 2002 hearing,                  
          challenge the underlying liability.  Petitioner failed to appear            
          at the hearing and did not attempt to schedule another hearing.             
          As a result, on June 9, 2003, respondent issued petitioner a                
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 (2003 notice of determination).                    
               The 2003 notice of determination stated that the underlying            
          liability “cannot be considered under this process” and “if you             
          want to dispute this determination in court, you must file a                
          petition with the United States Tax Court for a redetermination             
          within 30 days from the date of this letter.”  Petitioner did not           
          file a petition with the Court or otherwise dispute respondent’s            
          2003 notice of determination.  Respondent, however, did not                 
          proceed with the proposed collection action.                                
               On September 8, 2004, respondent mailed petitioner a Notice            
          of Federal Tax Lien Filing and Your Right to a Hearing Under IRC            











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