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respondent also assessed interest of $2,994.50 that had accrued
as of that date on such deficiency and such additions to tax.
(We shall refer to such assessed tax, assessed additions to tax,
and assessed interest, as well as any interest thereon as pro-
vided by law which respondent has not assessed but which accrued
after September 28, 1992, as petitioner’s unpaid liability for
1989.)
On September 28 and December 7, 1992, and January 11, 1993,
respondent sent petitioner notices of balance due with respect to
petitioner’s unpaid liability for 1989. On September 28, 1993,
respondent filed a notice of Federal tax lien with respect to
petitioner’s taxable year 1989.3 On January 10, 1997, a payment
of $192.55 was made by levy with respect to petitioner’s taxable
year 1989.4 On March 31, 1999, respondent issued a Final Notice,
Notice of Intent to Levy and Notice of Your Right to a Hearing
(notice of intent to levy) with respect to petitioner’s taxable
year 1989.
On or before April 29, 1999, in response to the notice of
intent to levy, petitioner filed Form 12153, Request for a
3The Federal tax lien filed on Sept. 28, 1993, was not a
collection action subject to sec. 6320. See sec. 301.6320-
1(a)(1), (b)(2) Q&A-B2, Proced. & Admin. Regs.; see also Nicklaus
v. Commissioner, 117 T.C. 117, 118 n.3 (2001).
4The levy made on Jan. 10, 1997, was not subject to sec.
6330. See sec. 301.6330-1(a)(1), (3) Q&A-A4, (4) Example 1,
Proced. & Admin. Regs.; see also Nicklaus v. Commissioner, supra.
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