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last known address. We lack jurisdiction to consider
petitioners’ claim. Respondent filed the notices of Federal tax
lien on August 27, 1992, and March 10, 1997. Section 6320
applies to collection actions initiated after January 19, 1999.
Internal Revenue Restructuring & Reform Act of 1998, Pub. L. 105-
206, sec. 3401, 112 Stat. 746; Hurford v. Commissioner, T.C.
Memo. 2002-94; see Parker v. Commissioner, 117 T.C. 63, 66 (2001)
(liens and levies are separate collection actions for purposes of
sections 6320 and 6330). Because the notices of Federal tax lien
were filed before January 19, 1999, they are not subject to
section 6320.
3. Conclusion
The above discussion rejects the grounds upon which
petitioners relied in their petition. Also, by failing to
respond to respondent’s motion, petitioners waived their right to
contest it. See Rule 121(d); Lunsford v. Commissioner, 117 T.C.
183, 187 (2001). We conclude that respondent’s determination to
proceed with collection of the tax liabilities assessed against
petitioners was not an abuse of discretion. Accordingly, we will
grant respondent’s motion for summary judgment.
An appropriate order and
decision will be entered.
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