- 8 - interest in the taxpayers’ property and potentially collecting the unpaid liability. In response to the notice of determination, petitioners timely filed their petition with this Court on February 9, 2006. OPINION I. Notices of Federal Tax Lien The record indicates there were two separate notices of Federal tax lien filed with respect to income tax liabilities in 1998. The first notice of Federal tax lien was filed with respect to the 1998 Form 5329 10-percent additional tax liability, and the second notice of Federal tax lien was filed with respect to the income tax liability for 1998 other than the 10-percent additional tax. The second notice of Federal tax lien did not include the 1998 Form 5329 10-percent additional income tax liability. Petitioners concede this Court lacks jurisdiction over the unpaid 1998 10-percent additional tax liability because they did not timely submit a request for an administrative hearing with respect to the first notice of Federal tax lien. See sec. 6320(b)(1); Orum v. Commissioner, 123 T.C. 1, 7-8 (2004), affd. 412 F.2d 819 (7th Cir. 2005). Petitioners timely submitted a request for an administrative hearing with respect to the second notice of Federal tax lien. See sec. 6320(b)(1). Although the first and second notices of Federal tax lien include a 1998 income tax liability, they coverPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007