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have used to obtain the amount of outstanding interest on his
1991 tax liability. In addition, respondent provided petitioner
with statements of the amount of interest outstanding at the time
the Forms 4340 were presented to him. Petitioner, who is an
experienced attorney, does not contend or allege that he in any
manner was prejudiced by respondent’s failure to provide the
amount of interest on the notices. Petitioner has not stated how
he may have been prejudiced by the omission of the amount of
outstanding interest on the three notices. The fact of the
matter is that petitioner was well aware of the amount of
interest and complained mightily about it.
In this record there was no prejudice on respondent’s
omission of the amount of interest on 3 of the 10 notices sent to
petitioner. Further, petitioner has not shown that he was
prejudiced by such omissions. Accordingly, we find it
unnecessary to consider what type of remedial action, if any,
would be appropriate.
VII. Whether Respondent’s Filing of Notices of Federal Tax
Lien was Improper Deprivation of Property or Property
Rights
Continuing with his shotgun approach to this proceeding,
petitioner contends that “The Fifth Amendment to the United
States Constitution provides that no person shall be deprived of
life, liberty or property without due process of law, which is
not a term without meaning.” Respondent’s use of statutorily
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