Jeffrey S. and Susan L. Duffield - Page 2

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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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