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that petitioners reported on 1988, 1989, 1990, 1992, 1993, 1995,
and 1996 Federal income tax returns.
On June 11, 1999, respondent issued a Notice of Intent to
Levy and Notice of Your Right to a Hearing. On July 8, 1999,
petitioners’ representative filed a Request for a Collection Due
Process Hearing (i.e., Form 12153) and requested a copy of the
assessments. In a letter dated January 19, 2000, respondent’s
Appeals officer asked petitioners to ratify the hearing request.
In a letter dated February 7, 2000, petitioners’ representative
provided the ratification and questioned “the existence of a
valid assessment document”. In an undated letter, the Appeals
officer replied: “Our office believes the information provided
is sufficient to determine that the necessary statutory and
administrative requirements have been met.” The Appeals officer
wrote further: “If, however, you wish to present relevant issues
relating to the unpaid tax in accordance with my earlier
correspondence, I have scheduled time on March 8, 2000, at 1:30
p.m. at the office address above.” Neither petitioners nor their
representative appeared at that time or requested that the
hearing be rescheduled.
On March 8, 2000, the Appeals officer obtained computer
transcripts (transcripts) of petitioners’ accounts. The
transcripts contained petitioners’ Social Security number and the
first four letters of their last name; monetary figures
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Last modified: May 25, 2011