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suspended. See sec. 6330(e)(1); sec. 301.6330-1T(g)(2), A-G1,
Temporary Proced. & Admin. Regs., 64 Fed. Reg. 3412 (Jan. 22,
1999). Thus, respondent is not time barred from collecting
petitioner’s Federal income tax liabilities for taxable years
1989 and 1990.
Petitioner has raised no other issue concerning his Federal
income tax liabilities for taxable years 1989 and 1990. We
conclude that petitioner is not entitled to the relief he seeks
for those years.
Has Petitioner Already Paid His Tax Liabilities for the Other
Taxable Years in Issue?
Petitioner contends that he has already paid his Federal
income tax liabilities for taxable years 1991, 1992, 1993, 1996,
and 1997. Because the validity of the underlying tax liability--
i.e., the amount of tax owed that remains unpaid--is properly in
issue for these taxable years, we review respondent’s
determinations for these years de novo. See Landry v.
Commissioner, 116 T.C. 60, 62 (2001).
Respondent introduced certified transcripts of account for
petitioner’s Federal income taxes for each of the taxable years
in issue. These transcripts reflect, among other things,
petitioner’s tax liabilities for taxable years 1991, 1992, 1993,
1996, and 1997 and all payments received for those liabilities.
The transcripts show that petitioner made some payments for his
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