NEW YORK (AP) _ It's doubtful Willie Nelson ever will record a song called ''Mama, Don't Let Your Babies Grow Up To Be Tax Liens.''

But the tax-battered country music star has embarked on a new satellite TV venture, ''The Outlaw Music Channel,'' in which he'll be a host and maybe sell a new album that on Wednesday he jokingly called ''The IRS Tapes.''

He said the Internal Revenue Service, to which he owes $16.7 million in back taxes and penalties, gave him permission to put out the album - actually called ''Who'll Buy My Memories.''

''It has 25 original songs and just me and my guitar,'' Nelson said in a telephone interview from Austin, Texas. ''If a couple of million people bought it, well, then, they could wipe out my debt immediately.''

Nelson, whose hits range from ''On the Road Again'' to a new version of Hoagy Carmichael's ''Stardust,'' announced the country music channel the day the IRS auctioned off his Evergreen, Colo., ranch for $650,000. The day before the IRS sold his ranch and house in Dripping Springs, Texas for $203,840. More Nelson properties face the auctioneer.

Nelson said the music channel will begin satellite transmission from Austin on Valentine's Day with a six-hour live concert featuring himself and such friends as Waylon Jennings, Dolly Parton, Johnny Cash and Kris Kristofferson.

The concert will air again on Feb. 15, and the channel's regular 12-hour programming will begin the next day, he said.

Although facing a financial burden that could buckle a buffalo, Nelson, 57, sounded in good spirits. He even laughed about his troubles with the tax dragon.

''It's really been good for me,'' he said. ''They're just putting me to work, really. I've just been sitting around, getting lazy, and all this has just kind of got me up and moving again.''

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