Gene and Ciao Newman - Page 8




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          were made, respondent issued to petitioners notices of balance              
          due informing petitioners that they owed taxes for the years in             
          question and requesting that they pay such amounts.  Petitioners            
          failed to pay the amounts owing.                                            
               C.  Respondent’s Collection Notices and Petitioners’                   
          Response                                                                    
               On August 14, 2000, respondent mailed to petitioner a Final            
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing in respect of his outstanding tax liabilities for 1993              
          and 1994.  Also on August 14, 2000, respondent mailed to                    
          petitioners a Final Notice--Notice of Intent to Levy and Notice             
          of Your Right to a Hearing in respect of petitioners’ joint tax             
          liabilities for 1995, 1996, and 1997.                                       
               On August 22, 2000, respondent mailed to petitioner a Notice           
          of Federal Tax Lien Filing and Notice of Your Right to a Hearing            
          Under IRC 6320 in respect of his tax liabilities for 1993 and               
          1994.  Also on August 22, 2000, respondent mailed to petitioners            
          a Notice of Federal Tax Lien Filing and Notice of Your Right to a           
          Hearing Under IRC 6320 in respect of petitioners’ joint tax                 
          liabilities for 1995, 1996, and 1997.  These two notices were               
          sent to petitioners in respect of notices of Federal tax lien               
          that respondent filed on August 17, 2000, with the County                   
          Recorder for Washoe County, Nevada.                                         








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