- 6 - February 18, 2004, respondent once again filed a Notice of Federal Tax Lien with respect to petitioners’ 1994 tax liability. Discussion Petitioners do not allege any irregularities in the assessment process of their 1994 tax liability, and we are satisfied that there were none. Furthermore, petitioners do not claim that respondent has failed to satisfy any of the requirements of section 6320 or section 6330, and we are satisfied that respondent has satisfied all of those requirements. Instead, the dispute between the parties in this case focuses primarily on whether petitioners have fully paid their 1994 tax liability. According to respondent, they have not, and respondent has determined to collect the outstanding portion of that liability by levy and through the notice of tax lien. Because the amount or existence of petitioners’ 1994 liability is properly at issue, we review de novo respondent’s determination as to the existence of that liability.4 Boyd v. Commissioner, 117 T.C. 127, 131 (2001); Landry v. Commissioner, 116 T.C. 60, 62 (2001). At the administrative hearing, petitioner claimed that all three of the checks delivered to respondent in March 1996 were intended in satisfaction of petitioners’ 1994 tax liability and 4 Respondent agreed to apply the $10,200 money order sent by petitioners in July 2001 to the 1994 tax liability.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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