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opinion, we shall treat respondent’s motion as a motion to
dismiss for lack of prosecution only.2
Background
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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