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FINDINGS OF FACT
When the petition was filed, petitioners resided in Goliad,
Texas. On December 11, 1997, respondent issued a notice of
deficiency relating to petitioners’ 1993, 1994, and 1995 Federal
income taxes, but petitioners did not petition for
redetermination of the deficiencies.
On February 16, 1999, respondent issued each petitioner a
Notice of Intent to Levy and Notice of Your Right to a Hearing.
On March 3, 1999, petitioners filed a Request for a Collection
Due Process Hearing (i.e., Form 12153) and contended that there
was no “valid summary record of assessment”. On March 31, 1999,
respondent’s Appeals officer obtained Certificates of Assessments
and Payments (i.e., Form 4340) relating to petitioners’ years in
issue. In a letter dated May 19, 1999, the Appeals officer
responded to petitioners’ request, scheduled a hearing, and typed
the following information at the top right side of the page:
Date and Time of Conference:
Thursday, June 10, 1999, at
9:00AM
Place:
IRS Appeals Office
5835 Callaghan Rd., STE 220
San Antonio TX 78228
Neither petitioners nor their counsel appeared or rescheduled the
hearing.
On June 18, 1999, the Appeals officer informed petitioners’
counsel by telephone that he was going to make a determination
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Last modified: May 25, 2011