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OPINION
THORNTON, Judge: Pursuant to sections 6320(c) and 6330(d),
petitioner filed a petition for review of an Appeals Office
determination sustaining a notice of Federal tax lien filing.1
The primary issue is whether petitioner is entitled to a section
6330 Appeals Office hearing with respect to his challenge of a
levy of his severance pay that occurred after the effective date
of section 6330 pursuant to a continuing wage levy that was
served on petitioner’s employer before the effective date of
section 6330.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. When petitioner filed his petition, he resided in
Oswego, New York.
Petitioner’s 1988-94 Tax Liabilities
Petitioner failed to pay Federal income taxes that he owed
for taxable years 1988, 1989, 1990, 1991, 1992, 1993, and 1994.
Respondent filed various Notices of Federal Tax Lien with respect
to these unpaid taxes.2 On or about October 21, 1997, respondent
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
2 In 1991, respondent filed a Notice of Federal Tax Lien for
petitioner’s 1988 and 1989 income tax liabilities. In 1994,
respondent filed a second Notice of Federal Tax Lien for
petitioner’s 1990, 1991, 1992, and 1993 income tax liabilities.
(continued...)
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Last modified: May 25, 2011