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one had explained how he could owe the amounts sought by
respondent. At that hearing, petitioner did not otherwise
contest the underlying tax liability or accept any of the payment
options proposed by respondent. Respondent determined that
petitioner’s wages should be levied in a notice of determination
concerning collection actions under section 6330 sent on July 8,
1999. In response, petitioner filed the petition in this case.
OPINION
A. The Notice of Lien
Petitioner contends that he is entitled to relief under
section 6320 from the notice of lien. We disagree. Section 6320
was first effective January 19, 1999. See Internal Revenue
Service Restructuring and Reform Act of 1998, Pub. L. 105-206,
sec. 3401(d), 112 Stat. 685, 750. Thus, section 6320 does not
apply to the notice of Federal tax lien issued on September 3,
1996.
B. Underlying Tax Liability
Respondent did not send a notice of deficiency to petitioner
for 1985, 1986, 1987, 1994, or 1995, but respondent did send a
notice of deficiency for 1992. Respondent does not contend that
petitioner may not raise issues relating to 1992 in this case, in
part because it is not clear whether petitioner received that
notice of deficiency. Thus, petitioner may challenge the
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