Stephen Daryl Royal - Page 7

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          1997,4 1998, 1999, and 2000.                                                
               To reflect the foregoing,                                              

                                             Decision will be entered for             
                                        respondent.                                   
























               4The notice of Federal tax lien that respondent prepared and           
          filed showed an unpaid liability of $858.74 for petitioner’s                
          taxable year 1997.  That notice was prepared on July 8, 2004,               
          before respondent (1) debited petitioner’s account for 1997 for             
          “FEES AND COLLECTION COSTS” of $6 and (2) credited that account             
          for the $853.74 payment that petitioner made on Aug. 12, 2004.              
          As of Aug. 16, 2004, petitioner’s account for his taxable year              
          1997 showed that he had an unpaid liability of $11.  That liabil-           
          ity, as well as any interest as provided by law, is the correct             
          amount of petitioner’s unpaid liability for 1997.                           




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