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Background
On October 19, 1998, respondent issued a collection letter
to William B. and Diane S. Meyer (petitioners) requesting that
they pay frivolous return penalties under section 6702 in the
amount of $500 for each of the taxable years 1996 and 1997. On
February 25, 1999, respondent issued to petitioners separate
final notices of intent to levy for the years 1996 and 1997.
Petitioners timely requested a hearing with the Internal
Revenue Service Office of Appeals (Appeals Office) pursuant to
section 6330(a). However, the appeals officer assigned to
petitioners' case did not offer or schedule a hearing because his
communications with petitioners led him to believe that they were
challenging respondent's collection efforts solely on
constitutional grounds.
On January 13, 2000, the Appeals Office issued to
petitioners separate Notices of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330
(determination letters) stating that all applicable laws and
administrative procedures had been met and that respondent would
proceed with collection against them for 1996 and 1997.
On or about February 4, 2000, petitioners wrote to the
Appeals Office to complain that they had not received a hearing
prior to the issuance of the above-described determination
letters. On February 9, 2000, Appeals Officer Tony Aguiar wrote
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Last modified: May 25, 2011