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initiation of a collection action for purposes of the effective
date provision of RRA 1998 section 3401(d).
We believe it was. Respondent asks the Court to interpret
the term “collection actions” in RRA 1998 section 3401(d) in a
general sense to include a lien and corresponding levy within a
single collection action. In accordance with that view,
respondent would have us hold that a collection action is
initiated at the same time for purposes of both sections 6320 and
6330. Respondent also would have us hold that the Court lacks
jurisdiction in this case on the ground that respondent commenced
the collection action against petitioner before the effective
date of section 6330 by filing the tax liens against petitioner’s
property.
We disagree with respondent’s interpretation. We do not
believe that a single act such as respondent’s notification to a
taxpayer of the filing of a tax lien is the initiation of a
single collection action for purposes of both sections 6320 and
6330. To be sure, Congress treated liens and levies separately
within the statutory scheme. See H. Conf Rept. 105-599, at 265
(1998), 1998-3 C.B. 747, 1019 (separate discussion as to liens
and levies). Compare sec. 6320 (liens) with sec. 6330 (levies).
Consistent with that treatment, we construe the term “collection
actions” in RRA 1998 section 3401(d) to require that liens and
levies be viewed as separate collection actions for purposes of
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