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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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