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liabilities. The transfer of these previous payments satisfied
petitioners’ tax liabilities for 1991, 1992, and 1993.
Therefore, the only remaining liabilities outstanding and at
issue in this case are for 1994, 1995, 1996, 1997, and 1999.
On November 11, 2000, a Final Notice--Notice of Intent to
Levy and Notice of Your Right to a Hearing was issued to
petitioners with respect to their unpaid 1994, 1995, 1996, 1997,
and 1999 income tax liabilities. On December 8, 2000,
petitioners timely filed a Form 12153, Request for a Collection
Due Process Hearing. In their request for a hearing, petitioners
questioned whether payments they previously made had been
properly applied against their 1994, 1995, 1996, 1997, and 1999
income tax liabilities.
On March 4, 2001, the Internal Revenue Service in Kansas
City, Missouri, sent a letter to petitioners advising that their
request for a collection due process hearing (CDP hearing) had
been received and that they would be contacted. By letter dated
April 13, 2001, petitioners were sent account summaries for their
1994, 1995, 1996, 1997, and 1999 income tax accounts.
Petitioners’ hearing request was assigned to an Appeals
officer. In a letter dated December 6, 2001, the Appeals officer
advised petitioners that he had scheduled a hearing for December
28, 2001, in Des Moines, Iowa.
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Last modified: May 25, 2011