Lloyd Pragasam - Page 4

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          not timely request a hearing in response to the March 19, 2001,             
          notice.                                                                     
          III.  1995, 1996, and 1997                                                  
               On November 6, 2003, respondent issued a Notice of Federal             
          Tax Lien Filing-Nominee, Transferee or Alter-Ego (Nominee Lien)             
          to Renaissance Health Systems LLC (Renaissance) in connection               
          with the 1995, 1996, and 1997 tax liabilities of petitioner.  On            
          November 6, 2003, respondent also issued a Notice of Federal Tax            
          Lien Filing and Your Right to a Hearing Under IRC 6320 to                   
          petitioner in connection with the 1995, 1996, and 1997 tax                  
          liabilities.                                                                
               On or about December 5, 2003, Renaissance Health Systems LLC           
          (Nominee, Transferee, or Alter-Ego, Lloyd A. Pragasam)2 submitted           
          a Form 12153, Request for a Collection Due Process Hearing,                 
          setting forth disagreement with the filed Notice of Federal Tax             
          Lien.  On February 25, 2004, the Appeals Office held a hearing              
          with petitioner’s representatives.                                          
               On June 14, 2004, respondent issued a Decision Letter                  
          Concerning Equivalent Hearing under Section 6320 and/or 6330 of             
          the Internal Revenue Code to petitioner.  On July 14, 2004,                 
          petitioner mailed a petition to this Court setting forth his                
          disagreement with the Decision Letter.                                      

               2  In light of our resolution of the case, we need not                 
          address respondent’s argument that this entity had no rights to             
          its own collection hearing or equivalent hearing.                           




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