William F. Urbano and Flota L. Urbano - Page 3

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          to review the determination of respondent’s Office of Appeals               
          (Appeals) sustaining respondent’s filing of a notice of Federal             
          tax lien (NFTL).  Respondent filed the NFTL to secure the payment           
          of $31,455.49 shown in his records to be due from petitioners as            
          of March 25, 2002, with respect to their 1993 Federal income tax.           
          The $31,455.49 is all attributable to interest (disputed                    
          interest) that respondent assessed on April 27, 1998.                       
          Respondent’s records show that petitioners’ liability for 1993              
          has increased to $43,818.27 as of August 6, 2002, to reflect                
          (1) fees and collection costs of $16 which respondent recorded on           
          April 15, 2002, and (2) unassessed accrued interest of                      
               Petitioners argue that they are not liable for the disputed            
          interest because they promptly paid respondent the $7,556.09 for            
          Federal income taxes, penalties, and interest that the revenue              
          agent who audited their 1993 through 1996 Federal income tax                
          returns had agreed with them was their total Federal income tax             
          liability for those years.  The revenue agent had set forth the             
          $7,556.09 on a Form 4549-CG, Income Tax Examination Changes,                
          which petitioners promptly signed and returned to the revenue               
          agent with their payment.  Respondent’s service center in Fresno,           
          California (service center), later concluded that the revenue               
          agent had understated the amount of interest petitioners owed by            

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