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liabilities for 1990, 1991, and 1993, acknowledged the Appeals
officer's willingness to let him do so but stated it would
nonetheless be futile, and addressed the liabilities only by
contending that he owed "but a small fraction" of the amounts
sought to be collected; (iv) contended that he had not filed a
return for 1992 and consequently was entitled to receive a notice
of deficiency before the underlying liability for that year could
be assessed or collected; (v) raised questions concerning
collection alternatives; (vi) contended that the notice of
determination was invalid and the 2003 supplemental notice was
improper; (vii) contended that improper ex parte contacts
occurred between respondent's Office of Chief Counsel and Appeals
after his case was remanded by this Court for a hearing; and
(viii) contended that Appeals failed to take steps to have
references to petitioner as a "tax protester" expunged from
respondent's files.
On March 3, 2004, Settlement Officer Waters issued a
supplemental notice of determination (2004 supplemental
determination) that (i) contained a verification that all
applicable laws and administrative procedures had been met, (ii)
considered the issues raised by petitioner, (iii) found that a
balancing of the need for efficient tax collection with
legitimate concerns that the collection action be no more
intrusive than necessary indicated the proposed levy was
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