- 2 - 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 figuresPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011