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for statutory interest. On the day the assessments were entered,
respondent issued to petitioners a notice of balance due
informing petitioners that they owed tax for 1997 and requesting
that they pay such amount. On April 24, 2000, respondent issued
a second notice of balance due to petitioners for 1997.
Petitioners failed to pay the amount owing.
On September 18, 2000, respondent mailed petitioners a Final
Notice-–Notice of Intent to Levy and Notice of Your Right to a
Hearing with regard to their tax liabilities for 1997. On
October 16, 2000, petitioners filed with respondent a Form 12153,
Request for a Collection Due Process Hearing. Petitioners’
request included a challenge to the validity of the assessments
and assertions that respondent failed to serve petitioners with a
valid notice and demand for payment or valid notice of
deficiency.
On February 26, 2001, Appeals Officer Tony Aegir conducted
an Appeals Office hearing in this matter that petitioners
attended. Petitioners were provided with a Form 4340,
Certificate of Assessments, Payments, and Other Specified
Matters, with regard to the taxable year 1997.
On April 4, 2001, respondent issued petitioners separate
Notices of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. The notices stated that the Appeals
Office determined that it was appropriate to proceed with the
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Last modified: May 25, 2011