Randy A. Belmont - Page 3

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          and the Internal Revenue Service is not entitled to change his              
          return.                                                                     
               On April 4, 2001, respondent mailed petitioner a Letter CP-            
          2000 stating: “WE’RE PROPOSING CHANGES TO YOUR 1999 TAX RETURN”,            
          in which respondent proposed changes to petitioner’s 1999 return            
          based upon reported income from third-party payors.  In response,           
          by letters dated April 9 and May 15, 2001, petitioner disputed              
          respondent’s authority to assess tax and asserted other tax-                
          protester arguments.                                                        
               On June 20, 2001, respondent mailed to petitioner a notice             
          of deficiency for 1999, in which respondent determined that                 
          petitioner and his wife owed a deficiency of $7,758, and a $1,552           
          accuracy-related penalty under section 6662(a).  In response, by            
          letter dated July 27, 2001, petitioner acknowledged receipt of              
          the notice of deficiency and again raised tax-protester                     
          arguments.  Petitioner did not file a petition with the Court to            
          redetermine the deficiency.                                                 
               Respondent assessed the tax, penalty, and interest on                  
          October 15, 2001.  On January 8, 2003, respondent filed a Notice            
          of Federal Tax Lien (NFTL) with the Recorder of Cuyahoga County,            
          Cleveland, Ohio, with respect to petitioner’s 1999 tax                      
          liabilities, and on January 13, 2003, respondent mailed                     
          petitioner a Letter 3172(DO) (Rev. 11-2000), Notice of Federal              







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