Francisco and Angela Aguirre - Page 3




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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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