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her unpaid tax liabilities for the years 1989 through 1992.3
There is no dispute that the above-described notices of intent to
levy were mailed to petitioners’ last known address. See sec.
6330(a)(2)(C). Both of the above-described notices of intent to
levy stated in pertinent part: “If you don’t pay the amount you
owe, make alternative arrangements to pay, or request Appeals
consideration within 30 days from the date of this letter, we may
take your property”.
On May 10, 1999, petitioners filed with the Internal Revenue
Service Office of Appeals (Appeals Office) a joint request for a
collection hearing, Form 12153, with respect to their tax
liabilities for the years 1987 through 1992 and 1997. Although
the Appeals Office concluded that petitioner Dudley Moorhous
failed to file his request for a hearing within the time
prescribed in section 6330, the Appeals Office granted petitioner
Dudley Moorhous a so-called equivalent hearing. See sec.
301.6330-1T(i), Temporary Proced. & Admin. Regs., 64 Fed. Reg.
3413 (Jan. 22, 1999).
On October 6, 2000, the Appeals Office issued to petitioner
Dudley Moorhous a “decision letter” stating that respondent would
3 The notice of intent to levy stated that petitioner
Dorothy Moorhous owed amounts from prior notices, additional
penalties, and interest totaling $17,909.98, $10,266.83,
$9,980.32, and $19,400.89, for the years 1989, 1990, 1991, and
1992, respectively.
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