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such a case. Petitioner suggests that we should determine the
value because: “The amount of the tax may be determined under
the authority of IRC sec. 6330.” The amount of the liability,
however, is not disputed in this case. Petitioner’s arguments go
only to “collectibility”.
Petitioner also seeks a determination of the value of the
pension plan subject to respondent’s liens as an advisory opinion
for the plan administrator. Nothing in section 6330 would extend
our reach that far.
Conclusion
We have considered the other arguments made by the parties,
including their dispute with respect to the standard of review of
the issues in this case. We have concluded that petitioner was a
resident of Florida at the time that the notices of lien were
filed and that, therefore, those liens were valid with respect to
his pension plan, the only asset identified as exempt from the
bankruptcy proceedings and as personal property with a situs at
petitioner’s residence. These conclusions would be unaffected by
resolution of the other disputes between the parties, and we
therefore decline to address them. We sustain the determination
of the Appeals office that it is appropriate for the IRS to
pursue collection by issuing a notice of levy pursuant to the
liens recorded in Florida in 1996.
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