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William J. McCorkle, pro se.
Pamela L. Mable, for respondent.
OPINION
HALPERN, Judge: This case is before the Court to review a
determination made by respondent’s Appeals Office (Appeals) that
respondent was warranted in filing a notice of Federal tax lien
(the notice of Federal tax lien or NFTL) against petitioner with
respect to his Federal income tax liability for 1996 (1996 tax
liability). We review that determination pursuant to sections
6320(c) and 6330(d)(1).1 Petitioner assigns error to Appeals’
determination on the grounds that Appeals erred in determining
that a $2 million remittance made by petitioner to the Internal
Revenue Service (IRS) on or about May 16, 1997 (the $2 million
remittance), did not satisfy the 1996 tax liability. Appeals
determined that the $2 million remittance did not satisfy the
1996 tax liability because that amount had been refunded to the
U.S. Marshals Service (Marshals Service) pursuant to an order of
the court in a non-tax criminal case involving petitioner. The
order specified that the $2 million was subject to criminal
forfeiture pursuant to 18 U.S.C. sec. 982 (2000). There being
little dispute as to the underlying facts, the parties have each
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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