Robin T. Hardie - Page 2




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          Federal income tax liability for 1999.  We review the                       
          determination pursuant to section 6330(d)(1).1                              
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code of 1986, as amended and as applicable             
          to this case, and all Rule references are to the Tax Court Rules            
          of Practice and Procedure.                                                  
                                     Background                                       
               This case was submitted for decision without trial pursuant            
          to Rule 122.  Facts stipulated by the parties are so found.  The            
          stipulation of facts filed by the parties, with attached exhibits           
          (the stipulation of facts), is included herein by this reference.           
               In their joint motion asking leave to submit this case under           
          Rule 122, the parties agreed that the case may be submitted on              
          the basis of the pleadings and the stipulated facts.                        
               By the petition, petitioner assigns error to the                       
          determination as follows:  “I believe the determination is                  
          incorrect and have already provided written evidence including              
          from third parties which contradicts key factual statements in              
          the IRS’s determination.  This evidence has been ignored by the             
          IRS.”  Attached to the petition is a copy of a two-page document            
          entitled “Notice of Determination Concerning Collection Action(s)           



               1  While petitioner checked the box on the petition                    
          indicating that he is seeking a redetermination of a deficiency,            
          clearly this action concerns a collection action, and we shall              
          treat it as such.                                                           





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