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to do so. Accordingly, on August 14, 2000, respondent assessed
the determined deficiency and accuracy-related penalty, as well
as statutory interest. On that same day, respondent sent
petitioner and his wife a notice of balance due, informing them
that they had a liability for 1997 and requesting that they pay
it. Petitioner and his wife failed to pay the amount owing.
Respondent sent petitioner and his wife a second notice of
balance due for 1997. Again, they failed to pay the amount
owing.
C. Respondent’s Final Notice and Petitioner’s Response
On February 8, 2001, respondent mailed to petitioner and his
wife a Final Notice--Notice of Intent to Levy and Notice of Your
Right to a Hearing in respect of their outstanding tax liability
for 1997.
On March 11, 2001, petitioner filed with respondent Form
12153, Request for a Collection Due Process Hearing.5 The
request, which was accompanied by a cover letter dated March 6,
2001, included, inter alia, a challenge to the existence of the
4(...continued)
According to your “Deficiency Notice”, listed above,
there is an alleged deficiency with respect to my 1997
income tax of $32,564.00 * * *, and if I wanted to
“contest this deficiency before making payment, “I
must” [sic] file a petition with the United States Tax
Court.”
5 The request was not executed by petitioner’s wife, nor
did it purport to be filed on her behalf.
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