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sent to petitioners with respect to a proposed levy to collect
liabilities arising with respect to tax year 1997.” As explained
in detail below, we shall grant respondent’s motion, as
supplemented.
Background
The record establishes and/or the parties do not dispute the
following:
A. Respondent’s Notice of Intent To Levy
On February 9, 2001, respondent mailed to petitioners a
Final Notice Of Intent To Levy And Notice Of Your Right To A
Hearing (notice of intent to levy) concerning petitioners’ unpaid
tax liability for the taxable year 1997. The notice of intent to
levy was sent to petitioners by certified mail at their last
known address, see sec. 6330(a)(2)(C),1 and was received by them
on February 12, 2001.
Petitioners did not respond to the notice of intent to levy
by paying their outstanding tax liability or making alternative
arrangements to pay, nor did petitioners request, within the
requisite period of time, consideration by respondent’s Appeals
Office. Accordingly, on or about May 1, 2001, respondent served
a notice of levy on petitioner Jennifer J. Nelson’s employer.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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