-3-
levy notice informed petitioners of their tax liability for 1996.
In addition, the final levy notice informed petitioners of (1)
respondent’s intent to collect that liability through a levy upon
their property pursuant to section 6331 and (2) petitioners’
right under section 6330 to a hearing with respondent’s Office of
Appeals (Appeals) to discuss the proposed levy. Enclosed with
the final levy notice was a copy of Form 12153, Request for a
Collection Due Process Hearing.
On April 23, 2001, respondent sent to each petitioner an
identical letter, Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under IRC 6320 (final lien notice) for 1996.
A Form 12153, Request for a Collection Due Process Hearing, was
enclosed with the final lien notice.
On April 30, 2001, petitioners mailed to respondent a Form
12153 requesting the referenced hearing. Petitioners attached a
letter “Request for a Collection Due Process Hearing.” That
letter stated:
Under IRC Section 6320(a)(3)(B), the individuals
name above do hereby request a hearing where both sides
may present lawful evidence to support their position.
* * *
* * * * * * *
Please perform the following and furnish the
documents requested for the 1996.
1. Abate your actions:
2. Provide me with a copy of the record of
assessment which is required by section 6203 (this is a
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011