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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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Last modified: March 27, 2008