Lloyd Pragasam - Page 7

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          assessments that have been made.  Id.  Further, respondent                  
          submitted copies of these notices of Federal tax liens, listing a           
          certified mail number, the letter dates, and the date of filing.            
               We also note that the address on the copies of the notices             
          of Federal tax liens is “11767 Knightsbridge PL, Loma Linda, CA             
          92354-4160.”  This is the address petitioner listed on his 1995,            
          1996, and 1997 tax returns.  On the basis of the record, we find            
          that the address used for the March 1, 2000, and March 19, 2001,            
          notices was petitioner’s last known address.                                
               The only evidence that petitioner presented is petitioner’s            
          testimony that he did not receive the notices.  The Court need              
          not accept at face value a witness’s testimony that is self-                
          interested or otherwise questionable.  See Archer v.                        
          Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a                    
          Memorandum Opinion of this Court; Weiss v. Commissioner, 221 F.2d           
          152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51; Schroeder v.            
          Commissioner, T.C. Memo. 1986-467.                                          
          II.  Collection Hearing                                                     
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice (i.e., the             
          hearing notice) of the filing of a notice of lien under section             
          6323.  Section 6320 further provides that the taxpayer may                  
          request administrative review of the matter (in the form of a               
          hearing) within a 30-day period.                                            






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