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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.
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