James Curtis Barrett - Page 3

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               This proceeding arises from a petition for judicial review             
          filed in response to a Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 (notice of              
          determination) sent to petitioner on April 8, 2004.  Pursuant to            
          sections 6320(c) and 6330(d), petitioner seeks review of                    
          respondent’s determination sustaining the filing of a notice of             
          Federal tax lien against petitioner.  The issue for decision is             
          whether petitioner may dispute the underlying tax liability for             
          any of the years in issue and, if so, whether any adjustment is             
               Some of the facts have been stipulated, and they are so                
          found, except as described below.  The record consists of the               
          stipulation of facts with attached exhibits, additional exhibits            
          admitted during trial, and the testimony of petitioner and Alyce            
          Wong, who is benefits supervisor for the San Francisco City and             
          County Employees Retirement System.  At the time of filing the              
          petition, petitioner resided in San Francisco, California.                  
               Respondent made assessments against petitioner for income              
          taxes and related penalties and interest for the taxable years              
          1994, 1995, 1996, 1997, and 1998.  Respondent also assessed for             
          collection costs for the taxable year 1994.                                 

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