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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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