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Petitioner did not pay the tax liability reported on his
1992 return. Based upon the liability reported on the return,
which does not include interest, additions to tax, or penalties,
petitioner and the revenue officer agreed to an installment
payment schedule at the time the return was prepared. The terms
of the installment agreement are unclear, but it appears that
petitioner originally agreed to pay $100 per month toward his
outstanding 1992 Federal income tax liability. We cannot tell
with any degree of certainty when the installment payments began
or ended, but as of the date of trial, petitioner had paid $2,514
towards his outstanding 1992 income tax liability.
On September 8, 2000, respondent issued to petitioner a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320 (the notice of lien). According to the notice of
lien, petitioner’s then-outstanding liability for 1992 Federal
income tax and related items totaled $10,132.48. Petitioner
timely submitted Form 12153, Request for Collection Due Process
Hearing. Petitioner stated in this request that he disagreed
with the underlying liability because the liability in dispute
was computed taking into account income that he neither earned
nor received; namely, the income reported on the Form 1099 issued
by State Farm. Petitioner’s administrative hearing was held on
February 13, 2001. During the hearing, petitioner reiterated his
challenge to the underlying liability. He did not raise any
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