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Federal income tax return and gave petitioners the opportunity to
submit a corrected return.
Respondent determined that petitioners had unreported wage
and self-employment income based on third-party information
returns submitted to respondent for each of the years 1996-2001.
Respondent later mailed notices of deficiency to petitioners for
1996-2001. Petitioners timely received the notices of
deficiency. They did not file a petition for redetermination
with the Tax Court because they asserted that the notices were
invalid.
C. Respondent’s Collection Notices and Petitioners’ Requests
for an Administrative Hearing
Respondent assessed the taxes and additions to tax
determined in the notices of deficiency for 1996-2001.
On September 23, 2000, respondent mailed to petitioner a
Final Notice of Intent to Levy and Notice Of Your Right to a
Hearing Under Section 6330 for 1996-1998. Although petitioner
contends that he submitted to respondent a Form 12153, Request
for Collection Due Process Hearing, challenging the levy notice,
the record does not include a copy of the request. In November
2003, respondent began to collect petitioners’ unpaid taxes for
1996-1998 by levying on petitioner’s wages.
In December 2003, petitioners filed with the Taxpayer
Advocate Service (TAS) a Form 911, Application for Taxpayer
Assistance Order, for 1996-2000. Petitioners also submitted to
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