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this opinion shall not be treated as precedent for any other
case.
This matter is before the Court on respondent’s motion for
summary judgment pursuant to Rule 121. The issue we must decide
is whether respondent’s Appeals Office abused its discretion in
determining to proceed with collection of petitioner’s tax
liabilities for taxable years 1998, 2000, 2001, and 2002 by lien.
Background
At the time of filing the petition, petitioner resided in
Clarksdale, Mississippi.
Petitioner filed an income tax return for taxable year 1998,
but failed to pay all of the liability reported on the return.
Petitioner failed to file income tax returns for 2000, 2001, and
2002. On October 27, 2003, respondent sent petitioner two
letters requesting that petitioner file income tax returns for
2000 and 2001. On November 26, 2003, respondent received from
petitioner returns for taxable years 2000 and 2001, which
reported zeros on every line of the return. Attached to the
returns for 2000 and 2001 were letters containing frivolous
arguments.
On February 27, 2004, respondent sent petitioner notices of
deficiency for 2000 and 2001. On July 19, 2004, respondent
assessed the tax liabilities, along with additions to tax and
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