Anthony D. Long - Page 2

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          opinion, we shall treat respondent’s motion as a motion to                  
          dismiss for lack of prosecution only.2                                      
               Petitioner resided in Los Alamitos, California, when the               
          petition in this case was filed.                                            
               Petitioner filed multiple 2001 Federal income tax returns              
          and amended returns at various times.  Respondent determined that           
          the positions taken by petitioner on his returns were frivolous.            
          As a result, respondent prepared a substitute return for 2001               
          under section 6020(b).  By a notice of deficiency dated                     
          November 12, 2003, respondent determined a deficiency in                    
          petitioner’s Federal income tax for 2001 of $11,994 and additions           
          to tax for 2001 under sections 6651(a)(1) and 6654(a) of                    
          $1,966.50 and $296.03, respectively.                                        
               On May 5, 2005, respondent mailed petitioner a Final Notice            
          of Intent to Levy and Notice of Your Right to a Hearing, and                
          petitioner timely requested a hearing under section 6330.  On               
          May 12, 2005, respondent mailed petitioner a Notice of Federal              
          Tax Lien Filing and Your Right to a Hearing Under IRC 6320, and             
          petitioner timely requested a hearing under section 6320.                   
          Respondent offered petitioner a face-to-face hearing if                     
          petitioner identified any relevant issues regarding the proposed            
          collection actions.  Petitioner refused to raise any relevant               

               2We deny respondent’s request for a penalty under sec. 6673.           

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