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At the Court hearing on November 17, 2003, Fran argued with
much vigor that, under her reading and close study of the
Internal Revenue Code and regulations, she and her husband are
not taxable on their wages and income. Fran pleads with the
Court to provide her with a persuasive written explanation, if
any exists, as to how she and her husband are liable for Federal
income taxes on her husband’s wages, on her fee income, on the
early retirement account distributions and on the interest
income.
Discussion
We note initially that because petitioners received a notice
of deficiency relating thereto petitioners’ Federal income tax
liability for 1997 is not before us in this action. Goza v.
Commissioner, 114 T.C. 176, 180-181 (2000). Our jurisdiction
herein is limited to a review of respondent’s discretion in
filing a notice of Federal tax lien to upgrade respondent’s
creditor status vis-a-vis petitioners’ other creditors. Sec.
6323; Sego v. Commissioner, 114 T.C. 604, 610 (2000).
On that narrow question as to respondent’s discretion we
hold for respondent. Petitioners have offered no basis on which
we could find any error in respondent’s discretionary
determination to proceed with the filing of a notice of Federal
tax lien relating to the 1997 Federal income tax deficiency,
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