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deficiency in petitioner’s Federal income tax of $5,421 and
additions to tax under sections 6651(a)(1) and 6654(a) of $752
and $133, respectively. For 2000, respondent determined a
deficiency in petitioner’s Federal income tax of $8,421 and
additions to tax under sections 6651(a)(1) and 6654(a) of $1,882
and $397, respectively.
On November 12, 2002, petitioner sent a letter to respondent
acknowledging receipt of the notices of deficiency. In the
letter, petitioner stated that before filing a petition with the
Tax Court or doing anything else with respect to the notices, “I
must first establish whether or not it was sent pursuant to law,
whether or not it has the ‘force and effect of law,’ and whether
you had any authority to send me the notice in the first place.”
Petitioner did not file a petition with this Court in
response to the notices of deficiency.
On September 5, 2003, respondent sent petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320. The notice of filing informed petitioner that a Federal
tax lien on all of his property had attached to secure payment of
the outstanding Federal income tax deficiencies for 1999 and
2000. The notice further informed petitioner of his right to a
hearing and under what circumstances the lien could be removed.
In response to the notice, petitioner mailed a Form 12153,
Request for a Collection Due Process Hearing, to respondent on
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