Shade D. Coleman III and Maria M. Coleman - Page 4

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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                      
               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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