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1, 844; S. Rept. 99-313, at 208 (1986), 1986-3 C.B. (Vol. 3) 1,
208.
Petitioner does not dispute the amount of his 1993 tax
liability as of July 10, 1997, and agrees that the June 12, 1997,
levy was appropriate and resolved petitioner’s tax liability for
1993. Petitioner has not alleged that respondent assessed
additional interest after July 10, 1997, with respect to
petitioner’s 1993 taxable year. Rather, petitioner’s dispute
concerns his claims that his property was levied upon twice for
1993 and that application of the July 20, 1997, levy proceeds to
his 1994 tax liability was erroneous because he did not receive
notice of respondent’s intent to levy for the 1994 year.
Respondent did not cause any delay in the payment of
petitioner’s 1993 tax liability. Petitioner has not alleged any
error on the part of respondent prior to July 10, 1997, the date
on which his 1993 tax liability was resolved. Although it
appears that respondent mistakenly levied on petitioner’s
property twice for his 1993 tax liability,8 respondent promptly
8Petitioner alleges that respondent wrongfully levied on
petitioner’s property because notice of intent to levy was not
provided for the 1994 year. The evidence before us indicates
that respondent levied on petitioner’s property twice for
petitioner’s 1993 tax liability, but that proceeds from the
second levy were used to satisfy petitioner’s undisputed tax
liabilities for subsequent years. Petitioner brought this action
under sec. 6404 seeking review of respondent’s failure to abate
interest. In the instant case, we lack jurisdiction to decide
petitioner’s claim that respondent made a wrongful levy. See
sec. 6404(i); Krugman v. Commissioner, 112 T.C. 230, 236 (1999).
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