Gene and Ciao Newman - Page 10




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          discuss collection alternatives.                                            
               E.  Respondent’s Notices of Determination                              
               On April 2, 2001, respondent’s Appeals Office issued to                
          petitioner separate Notices of Determination Concerning                     
          Collection Action(s) Under Section 6320 and/or 6330 with regard             
          to his tax liabilities for 1993 through 1997.  In the notices,              
          the Appeals Office stated that respondent’s determination to                
          proceed with collection by way of levy should be sustained and              
          that the filing of the notices of Federal tax lien was                      
          appropriate.                                                                
               Also on April 2, 2001, respondent’s Appeals Office issued to           
          petitioner Ciao Newman a Notice of Determination Concerning                 
          Collection Action(s) Under Section 6320 and/or 6330 with regard             
          to her tax liabilities for 1995 through 1997.  In the notice, the           
          Appeals Office stated that respondent’s determination to proceed            
          with collection by way of levy should be sustained and that the             
          filing of the notice of Federal tax lien was appropriate.                   
               F.  Petitioners’ Petition and Motion To Dismiss                        
               On April 30, 2001, petitioners filed with the Court a                  
          Petition for Lien or Levy Action seeking review of respondent’s             
          notices of determination.2  The petition includes the following             
          allegations:  (1) The Appeals officer failed to obtain                      


               2  At the time that the petition was filed, petitioners                
          resided in Reno, Nevada.                                                    






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