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In 1999, respondent sent to petitioners a Notice of Intent
to Levy and Notice of Your Right to a Hearing relating to
petitioners’ 1992-94 tax years. Petitioners then filed a Form
12153, Request for a Collection Due Process Hearing, for those
tax years.1 Petitioners requested the hearing solely to dispute
the correctness of their underlying tax liabilities. On August
22, 2000, respondent sent petitioners a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(the determination letter), in which respondent stated that
collection from petitioners of their tax liability for 1992-94
would proceed. On September 5, 2000, petitioners filed a
petition for lien or levy action under section 6320(c) or
6330(d).
Respondent filed a motion for summary judgment on April 13,
2001. On April 17, 2001, the Court issued an order directing
petitioners to file a response to respondent's motion. The order
included a reminder to the parties that the case would be called
from the calendar at the April 30, 2001, Los Angeles, California,
trial session. Petitioners failed to file a response to
respondent's motion, and they did not attend, or have someone
appear on their behalf at, the calendar call.
1 The record does not indicate whether respondent conducted
a hearing in petitioners’ case.
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Last modified: May 25, 2011