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Commissioner regarding his “1990 income tax liability.” On March
10, 1998, the bankruptcy court denied the request, ruling that
petitioner’s “1990 tax liabilities were not discharged in * * *
[the] bankruptcy case.” In re Katz, No. 90-39248-BKC-RAM (Bankr.
S.D. Fla., Mar. 10, 1998). On May 14, 1998, with regard to the
original tax dispute, we entered a decision stipulated by the
parties setting out the amounts of the tax deficiency and
additions to tax and providing for statutory interest.4 See Katz
v. Commissioner, Docket No. 21359-96 (May 14, 1998). The amounts
of the tax deficiency and additions to tax redetermined in the
decision were much lower than the amounts set forth in the notice
of deficiency. Subsequently, respondent assessed the tax
deficiency, additions to tax, and interest.
On February 23, 1999, respondent filed a Notice of Federal
Tax Lien (lien filing) with regard to the amounts assessed for
the 1990 tax year in the county recorder’s office for Palm Beach
County, Florida. On February 27, 1999, respondent transmitted to
petitioner a “Notice of Federal Tax Lien Filing and Your Right to
a Hearing under IRC 6320”. On or about March 31, 1999, pursuant
to section 6320(b), petitioner requested an Appeals hearing from
respondent’s Appeals Office. In his request, petitioner
contested the entire amount listed in the lien filing.
4 The decision provided: “It is further stipulated that
interest will be assessed as provided by law on the deficiency
and additions to tax due from the petitioner.”
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