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that petitioner cannot be assessed and the levied funds cannot be
applied to satisfy the assessments. Moreover, petitioner has not
executed any consent to an assessment and collection of the
amounts determined by respondent in the notice of deficiency for
1986 and 1987.
As noted earlier, when petitioner filed her 1987 return, she
directed on the return that part of the $4,397 tax due should be
paid by application of $2,899.89 that respondent realized from a
levy on Crossland Savings, a bank or financial institution that
held an account for petitioner. Respondent did not allow the
$2,899.89 as a payment of petitioner's 1987 tax liability, and,
on September 17, 1993, that amount was transferred by the IRS out
of petitioner's 1987 account and applied toward payment of a 1989
tax assessment against petitioner. Petitioner contends that the
$2,899.89 constituted a payment of part of her 1987 tax, and the
deficiency determined by respondent is overstated by that amount.
The liability for payment of a tax (or the right to enforce
collection thereof by respondent) arises when the tax is assessed
pursuant to sections 6201 through 6210. At the time petitioner
filed her 1987 income tax return, respondent was holding sizeable
amounts of moneys for petitioner's account, which respondent had
obtained previously through several levies.
No reasons were stated in the notice of deficiency as to why
the $2,899.89 did not constitute a payment of the 1987 tax shown
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