Bradley W. Bean - Page 2

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          section 6330(d), petitioner seeks review of respondent’s                    
          determination.  The issues for decision are whether respondent              
          abused his discretion in sustaining the filing of a Federal tax             
          lien and whether the Court should impose a penalty under section            
          6673(a).                                                                    
                                  FINDINGS OF FACT                                    
               At the time the petition was filed, petitioner resided in              
          Methuen, Massachusetts.                                                     
               On April 25, 2000, respondent received petitioner’s 1999               
          Federal income tax return.  Petitioner reported tax withheld of             
          $2,235, claimed a refund of $2,235, and entered zeros on all                
          other lines.  Petitioner attached to the return a two-page letter           
          disputing the constitutionality of the Federal income tax laws              
          and claiming that no law made him liable to pay tax.  Respondent            
          informed petitioner that his 1999 return could not be filed.                
               On June 29, 2001, respondent received petitioner’s 2000                
          Federal income tax return.  Petitioner reported tax withheld of             
          $895, claimed a refund of $895, and entered zeros on all other              
          lines.  Petitioner attached to the return a two-page letter                 
          identical to the letter attached to his 1999 return.                        





               1(...continued)                                                        
          the Internal Revenue Code, as amended.  All amounts are rounded             
          to the nearest dollar.                                                      




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