- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007