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On April 28, 2004, respondent filed notices of Federal tax
lien with respect to petitioner’s taxable years 1980 through
1984, 1992, and 1997. (We shall refer to the notices of Federal
tax lien filed with respect to petitioner’s taxable years 1980
and 1981 as the 1980 tax lien and the 1981 tax lien, respec-
tively.)
On May 3, 2004, respondent issued to petitioner a notice of
Federal tax lien filing and your right to a hearing (notice of
tax lien) with respect to his taxable years 1980 through 1984,
1992, and 1997.
On May 25, 2004, the Bankruptcy Court entered an order in
Mr. Hassell’s bankruptcy case holding Mr. Hassell in civil
contempt of court. That order provided in pertinent part:
IT IS ORDERED, and the Court finds, that the
Debtor Melvin Ray Hassell is in civil contempt of
Court, for not complying with this Court’s February 20,
2004 Order on United States’ Motion to Strike, for
Injunctive Relief, and Sanctions against Melvin R.
Hassell, because after February 20, 2004, Mr. Hassell
filed with this Court at least three pleadings wherein
he attempted to relitigate his federal tax liabilities
or to challenge the amount thereof.
On June 4, 2004, in response to the notice of tax lien,
petitioner filed Form 12153, Request for a Collection Due Process
Hearing (Form 12153), and requested a hearing with respondent’s
Appeals Office (Appeals Office). Petitioner attached a document
to his Form 12153 that is wholly irrelevant to the questions
raised in respondent’s motion.
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