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notice of balance due, informing them that they had liabilities
for 1997 and 1998 and requesting that they pay those liabilities.
Petitioner and his wife failed to pay the amounts owing.
On April 16, 2001, respondent sent petitioner and his wife a
second notice regarding their liabilities for 1997 and 1998.
Once again, petitioner and his wife failed to pay the amounts
owing.
D. Respondent’s Final Notice and Petitioner’s Response
On September 5, 2001, respondent mailed to petitioner and
his wife a Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing (the final notice) in respect of their
outstanding tax liabilities for 1997 and 1998. Petitioner
received the final notice on September 7, 2001.
On October 1, 2001, petitioner filed with respondent a Form
12153, Request for a Collection Due Process Hearing, for each of
the taxable years 1997 and 1998.5 The requests, each of which
was accompanied by a lengthy cover letter dated October 1, 2001,
included, inter alia, a challenge to the existence of the
underlying tax liabilities,6 as well as allegations that
5 Neither request was executed by petitioner’s wife, nor
did either purport to be filed on her behalf.
6 For example, the requests allege that “there is no
statute requiring me ‘to pay’ the income taxes at issue” and that
“No law authorizes the IRS to claim that I owe more in income
taxes than the ‘zero’ I reported on my * * * income tax return.”
In this regard, the requests also assert that
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