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Respondent treated the Forms 1040X for 1990 and 1991 as
claims for refund which he formally disallowed as untimely by
letter on April 25, 1997. Respondent treated the Form 1040X for
1993 as a frivolous return and assessed a frivolous return
penalty under section 6702 on October 27, 1997.
Respondent issued a notice of deficiency to petitioner for
1996 on June 5, 1998, determining a deficiency in income tax of
$7,405, as well as additions to tax under sections 6651(a)(1) and
6654. No petition was filed in response to the notice of
deficiency, and respondent assessed the amounts determined in the
notice, as well as interest (collectively, the 1996 liability),
on November 9, 1998. The 1996 liability was unpaid at the time
of trial.
On March 7, 2001, a Letter 1058, Final Notice - Notice of
Intent to Levy and Notice of Your Right to a Hearing, was mailed
to petitioner concerning the 1990, 1991, 1992, 1993, and 1996
liabilities. Petitioner timely filed a Form 12153, Request for a
Collection Due Process Hearing, for all of the aforementioned
liabilities. Petitioner's Form 12153 also requested a hearing
with respect to notices of Federal tax lien filing regarding the
foregoing liabilities.
By letter dated July 9, 2001, the Office of Appeals
(Appeals) notified petitioner that his request had been assigned
to Appeals officer Lawrence Ford (AO Ford) and requested that
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