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to the notice relating to her taxable year 1988 or the notice
relating to her taxable year 1989.
On February 6, 1995, respondent assessed petitioner’s tax,
as well as additions to tax and interest as provided by law, for
her taxable year 1988. On February 6, 1995, respondent also
assessed petitioner’s tax, as well as interest as provided by
law, for her taxable year 1989. (We shall refer to those as-
sessed amounts, as well as interest as provided by law accrued
after February 6, 1995, as petitioner’s unpaid liabilities for
1988 and 1989.)
Respondent issued to petitioner the notices and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid liabilities for 1988 and 1989.
On or about June 22, 2001, respondent filed a notice of
Federal tax lien (tax lien filing) with the Recorder of Deeds,
Cook County, Chicago, Illinois, with respect to, inter alia,
petitioner’s unpaid liabilities for 1988 and 1989. The tax lien
filing listed petitioner’s name and the address of her residence.
On June 28, 2001, respondent issued to petitioner a notice
of Federal tax lien filing and your right to a hearing (notice of
tax lien) with respect to, inter alia, her unpaid liabilities for
1988 and 1989. On July 1, 2001, respondent issued to petitioner
a final notice of intent to levy and notice of your right to a
hearing (notice of intent to levy) with respect to, inter alia,
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