-3-
Your Right to a Hearing” (final notice). The final notice
informed petitioners of (1) respondent’s intent to levy upon
their property pursuant to section 6331 and (2) petitioners’
right under section 6330 to a hearing with respondent’s Office of
Appeals (Appeals). Enclosed with the final notice was a copy of
Form 12153, Request for a Collection Due Process Hearing. On
December 6, 1999, petitioners mailed to respondent a Form 12153
requesting the referenced hearing. Petitioners attached to the
form an explanation of their disagreement with the proposed levy.
The explanation stated:
Income. (1) There was a failure to generate an
assessment list; (2) There was a failure of the
Commissioner to certify and transmit the assessment
list (3) There was a failure to record the assessment;
(4) failure to provide record of assessment; and,
(5) failure to send Notice of Assessment.
On May 4, 2000, the Appeals officer sent to Carlin Bartschi
(Mr. Bartschi) a letter informing him that Appeals had scheduled
the requested face-to-face hearing for May 19, 2000. The Appeals
officer also sent a copy of this letter to Joyce Bartschi. On
May 13, 2000, Mr. Bartschi, a medical doctor, responded to the
Appeals officer with a letter requesting that Appeals reschedule
the hearing for the last week of July. Mr. Bartschi stated in
his letter that he and his wife would be out of town on May 19,
2000. Mr. Bartschi also stated in his letter that petitioners
could subsequently be requesting an even later hearing date
because they were: (1) Waiting on responses to their requests
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Last modified: May 25, 2011