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IV. Whether Respondent Complied With the Notice
Requirements for the Filing of a Notice of Federal
Tax Lien, and Whether the Appeals Officer Was Required
To Provide Petitioner With All Documents Maintained by
Respondent With Respect to Him
Petitioner, on brief, makes the barebones argument that
respondent “must comply with notice requirements when filing a
lien.” To make his point, petitioner, on brief, argues that
“Notice of the filing of the lien was not given within five days
in that the liens were filed on August 3, [sic]2005 and the
notice was not dated until August 10, [sic]2005.” In response,
respondent points out that the NFTLs were actually filed with the
County Chancery Courts on August 6, 2004, and the Notices sent to
petitioner were mailed on August 4 and August 10, 2004. The
record bears out respondent on this point. We again note
petitioner’s shotgunlike approach and his propensity to grasp at
straws without providing any meaningful support for his position.8
Petitioner contends that the Internal Revenue Service “must
provide a taxpayer with documents related to him or her in its
file.” Here again, this unsupported contention is without
specificity or distinction. Respondent sent numerous notices,
publications, and other materials to petitioner and provided him
with summaries, Certificate of Assessments and Payments, Forms
4340, with respect to his 1991 tax account. There is no other
8 We also note that petitioner failed to acknowledge that
the notice period is 5 business days, which even under
petitioner’s flawed approach could have explained the difference.
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