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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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