1. Whether Petitioner is entitled to relief from a
judgment and orders from the Second Circuit
court, which conflicts with a decision of this Court
or has so far departed from the accepted and usual
course of judicial proceedings, or sanctioned such
a departure by a lower court?

2. Whether the District Court violated Petitioner's
substantive and procedural due process when it
presided over an action to reduce a lien to judg
ment beyond the 6-year statute of limits and its
corresponding 10-year collection extension period?

3. Did the Government deprive Petitioner of his due
process when it failed to timely notify him (within
60-days of the assessment) of its intent to assess
corporate tax liability against him or give him the
opportunity to timely challenge the liability (pro
vide 90-day demand notice)?

4. Whether the record met the substantial evidence
threshold that a reasonable mind could accept as
adequate to support its conclusion, relative to the
accuracy of dueling assessments and the agencies
confirmation that the lien statute had expired?

5. Whether the Government is subject to damages
under Biven's for clearly violating established
statutory or constitutional rights when it failed to
disclose exculpatory evidence and release an im
proper lien.

Whether Petitioner is entitled to relief from a judgment and orders from the Second Circuit court