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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
$12,346.78.
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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Last modified: May 25, 2011