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Notice of Your Right to a Hearing, and on May 4, 2004, respondent
filed a notice of Federal tax lien on petitioner’s property with
the County Clerk for Harris County. In his notice dated May 11,
2004, advising petitioner of the lien, respondent provided
petitioner with detailed information about the amounts of tax
that were owed, the related tax periods, and citations of the
Code sections that authorize the lien filing.
On June 14, 2004, petitioner requested a hearing under
section 6320 with respect to the lien, alleging that there were
erroneous dates of assessment and “amounts unjustifiably
entered.”4 The request for a hearing referenced a letter dated
February 4, 2004, that petitioner had written to respondent in
response to respondent’s final notice of intent to levy. In that
letter, petitioner advanced frivolous arguments as to why
respondent’s collection activities should not go forward.5
4Petitioner’s request for a hearing did not include the
proposed levy action and would not have been timely with respect
to it. See secs. 6330 and 6331. It appears that respondent
agreed to an equivalent hearing with respect to the levy. While
it is not clear whether or when an equivalent hearing was held,
respondent did not issue a notice of determination with respect
to the levy action. Petitioner has not asked us to consider the
levy action here, and we would not have jurisdiction to do so.
See sec. 6330(d).
5Petitioner, in his Feb. 4, 2004, letter, did not request a
hearing but alleged that the levy action interfered with his
right to due process because he had filed a civil action in the
U.S. District Court for the District of Columbia. (In his
pretrial memorandum, petitioner further describes the District
Court case as one involving a “Privacy Act Request”. We note
(continued...)
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