Thomas Olan Maxton, Jr. - Page 2




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          determining that a Federal tax lien was appropriately imposed on            
          petitioner’s property with respect to tax owed for tax years                
          1991, 1992, and 1993.                                                       
                                     Background                                       
               At the time petitioner filed the petition, he resided in               
          Pasadena, Texas.  Petitioner failed to file Federal income tax              
          returns for the tax years 1991, 1992, and 1993.  Consequently,              
          respondent prepared a substitute for return for each of those               
          years.  On May 6, 1997, respondent issued a notice of deficiency,           
          determining deficiencies of $14,823 for 1991, $33,329 for 1992,             
          and $25,502 for 1993.  Respondent also determined that petitioner           
          was liable for additions to tax under sections 6651(a)(1) and               
          6654 of $2,508 for 1991, $8,279 for 1992, and $7,222 for 1993.              
          Petitioner did not judicially challenge these determinations.2              
          On October 29, 1997, respondent assessed tax and additions to tax           
          for tax years 1991, 1992, and 1993 as shown in the notice of                
          deficiency, as well as interest thereon.  On January 14, 2004,3             
          respondent mailed petitioner a Final Notice of Intent to Levy and           


               2Petitioner’s response to the notice of deficiency was to              
          retain an attorney, J. Hamilton McMenamy, who, acting on behalf             
          of petitioner, sent a letter to respondent dated July 11, 1997,             
          raising frivolous arguments in regard to the notice of                      
          deficiency.  For example, the letter demanded to know what Code             
          section imposes a tax on petitioner and the specific tax forms              
          petitioner was required to file to report his tax.  The letter              
          suggested that petitioner had no duty to pay taxes.                         
               3It appears that petitioner may have filed for bankruptcy at           
          some point during the 1997-2004 interim.                                    





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