Background, above, and we agree with respondent that petitioner has failed to raise a justiciable issue. Rule 331 addresses the commencement of a levy action. under section 6330(d). Such an action is commenced by the filing of a petition, Rule 331(a), and Rule 331(b) specifies the content of the petition. Rule 331(b)(4) and (5) requires the petition to contain: (4) Clear and concise assignments of each and every error which the petitioner alleges to have been committed in the notice of determination. * * * (5) Clear and concise lettered statements of the facts on which the petitioner bases each assignment of error. Pursuant to section 6330(c)(2)(B), petitioner was entitled to challenge at his Appeals Office hearing the existence or amount of the underlying tax liabilities for 1994 and 1996 giving rise to the assessments. If the validity of those underlying tax liabilities is properly at issue, we review the matter de novo. Sego v. Commissioner, 114 T.C. 604, 610 (2000). For the validity of those underlying tax liabilities to be properly at issue, however, petitioner must comply with Rule 331. His pleading must contain a sufficient specificity of facts so that the Court can conduct a meaningful hearing to determine whether respondent can proceed with the collection of those liabilities. Petitioner's averments make clear that he disagrees with his income tax liabilities as shown on the returns. However, other than claiming that the returns contain false and fraudulent information and may be based on incorrect written advice from the IRS, petitioner fails to specify the basis of his disagreement; i.e., he fails to identify the items of income, deduction, or credit, or the computations, that are incorrect. Without such specificity, how could respondent possibly mount a defense, and what precisely is it that the Court is to decide? Apparently, the root of petitioner's disagreement with the returns is his dispute with certain record companies over royalties. Petitioner has tried to involve respondent in that dispute by asking respondent to subpoena information from the record companies so that he could make what he believes would be more accurate returns. Respondent claims that neither section 6330 nor any other provision of the Internal Revenue Code authorizes the IRS to aid petitioner as he has requested and there is no evidence that Congress intended taxpayers to use section 6330 to redress grievances against third parties. Respondent further claims that petitioner presented no evidence of the proper amount of royalties due him, nor any evidence supporting his claim that the record companies violated his copyrights or that he even has copyrights to any songs. Petitioner, in his opposition to the motion, does not contradict any of those assertions. Petitioner may well have a dispute with the record companies, and the returns may or may not be accurate, but petitioner has placed nothing before us regarding the underlying liabilities that we can properly adjudicate. Like the taxpayers in Horn v. Commissioner, T.C. Memo. 2002-207, and Smith v. Commissioner, T.C. Memo. 2002-59, whose efforts to dispute their "self-assessed" liabilities we rejected, petitioner was not prepared to allege and prove the facts showing his returns were incorrect. See also Montgomery v. Commissioner, supra at 19 (Marvel, J., concurring). We conclude that respondent's second ground (together with his third ground, discussed next) justifies summary judgment. IV. Petitioner Has Failed To Aver Facts Showing Any Other Error in the Determination Although petitioner avers errors in the assessment procedures and in other procedures and improper execution of levies, he sets forth no factual basis for those claims. Indeed, respondent has yet to make any levies with respect to the assessments. Except as we have discussed with respect to the Appeals officer's refusal to consider the accuracy of the assessments, we see no error in the determination. V. Conclusion Petitioner has failed to put before us grounds on which we could find that the Appeals officer erred in the determination. On that basis, respondent is entitled to summary disposition in his favor. To reflect the foregoing, An appropriate order and decision will be entered for respondent. GREGORY IANNONE, PETITIONER v. COMMISSIONER OF Docket No. 17412-02L. Filed April 19, 2004. P filed a timely petition for judicial review pursuant to sec. 6330(d)(1)(A), I.R.C., in response to a notice of determination by R to proceed with collection of assessed tax liabilities for 1987, 1989, and 1991. Subsequently, the Court granted respondent's motion to dismiss for lack of jurisdiction and to strike as to taxable year 1987. Held: For the purpose of this collection proceeding, the Appeals officer agreed to assume that petitioner's 1989 and 1991 tax liabilities were discharged in bankruptcy. We will not remand this case for a clearer articulation of the Appeals officer's determination relating to petitioner's bankruptcy discharge. Held, further, the existing Federal tax lien that attached to P's property when he filed his bankruptcy petition was not extinguished as a result of his bankruptcy discharge. Secs. 6321 and 6322, I.R.C., applied. Held, further, no exemption to levy applies in this case. Held, further, R may proceed with collection by levy as determined in the "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330". Santo J. Bonanno, for petitioner. NIMS, Judge: This case arises from a petition for judicial review filed in response to a "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTIONS(S) UNDER SECTION 6320 AND/OR 6330" (notice of determination). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. At the time the petition was filed in this case, petitioner resided in Ringwood, New Jersey. On June 16, 1997, petitioner filed a chapter 7 bankruptcy petition, case no. 97-27076. Petitioner was granted a discharge in his bankruptcy case on September 29, 1997. On January 12, 2002, respondent issued to petitioner two letters entitled "Final Notice-Notice of Intent to Levy and Notice of Your Right to a Hearing". In response, petitioner sent to respondent a Form 12153, Request for a Collection Due Process Hearing, dated January 15, 2002. The Appeals officer assigned to review petitioner's case received and reviewed copies of transcripts for petitioner's income tax liabilities for 1989 and 1991 in order to verify that the requirements of any applicable law or administrative procedure had been met. On July 9, 2002, petitioner met with the Appeals officer to discuss the case, but they were unable to resolve the issues. On October 8, 2002, respondent issued to petitioner the aforementioned notice of determination concerning his 1987, 1989, and 1991 income tax liabilities. In pertinent part, the notice of determination states: Based on the facts available, the required procedures have been followed and the notice of intent to levy is proper and appropriate. A conference was held on July 9, 2002 and we agreed that the taxes were dischargeable, however the exempt property was subject to our lien and levy. You were advised to consider collection alternatives and have failed to do so. It is therefore recommended, that the action by Compliance to levy will be sustained with respect to the exempt property listed in your bankruptcy case number 97-27076. An attachment to the notice of determination, "Attachment— Letter 3193, Notice of Determination", in pertinent part, states: IRC 6321 provides a statutory lien when a taxpayer neglects or refuses to pay a tax liability after notice and demand. Transcripts of your account show that the IRS issued a first notice July 19, 1991 and a fourth notice December 16, 1991 on your 1040 198712 [Federal income tax liability for the 1987 tax year], a first notice April 26, 1993 and a fourth notice May 17, 1993 on your 1040 198912 [Federal income tax liability for the 1989 tax year], a first notice May 16, 1994 and a fourth notice June 6, 1994 on your 1040 199112 [Federal income tax liability for the 1991 tax year]. The latest transcript in the file indicates the only periods remaining open are the 198912 [the 1989 tax year] and 199112 [the 1991 tax year] * * * A formal conference was held on July 9, 2002 and you challenged the existence of the liability, and appropriateness of the levy action by Compliance. It was determined that the bankruptcy may have discharged the 1040 [Federal income tax] liabilities for 198712, 198912, and 199112 [the 1987, 1989, and 1991 tax years]. However, there was exempt property listed in the amount of $41,500 in Schedule C of your voluntary [bankruptcy] petition and you were advised that further research was necessary to determine if our federal tax lien attaches to that exempt property for purposes of levy action. *** * You filed a Chapter 7 Bankruptcy Petition on June 16, 1997, bearing case number 97-27076 listing all years from *** [1987] through *** [1993]. You further stated the IRS never objected to discharge for any reason. Discharge for all years was granted by Order dated September 29, 1997. There was also some indication that the 1040 198912 and 1991[1]2 [Forms 1040 for the 1989 and 1991 tax years] were not filed and you did not keep copies after seven years. Systemic records show that the IRS filed these returns as substitute for returns, based on information documents received. Nonetheless, it was agreed upon at our conference that the liabilities for your 1040 for 198712, 198912, and 199112 [Federal income tax liabilities for 1987, 1989, and 1991] might be dischargeable. After further research it has been determined that notwithstanding the fact that your income taxes may be dischargeable, the Service's liens survive the bankruptcy. *** Furthermore, Section 522(C)(2)(B) expressly provides that exempt property remains subject to properly filed tax liens even though the underlying tax claims may have been discharged. *** The debtor's schedules indicate there is a 401K plan with, Unitex Textile, to which the Service's liens would attach. * * * In response to the notice of determination, petitioner filed the petition in the instant case with respect to the 1987, 1989, and 1991 tax years. On September 22, 2003, respondent filed a motion to dismiss for lack of jurisdiction and to strike as to taxable year 1987. On September 22, 2003, the Court granted respond ent's motion. OPINION I. General Rules Section 6331(a) authorizes the Commissioner to levy against property and property rights where a taxpayer liable for taxes fails to pay them within 10 days after notice and demand for payment is made. Section 6331(d) requires the Secretary to send notice of an intent to levy to the taxpayer, |