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they owed tax for 1996 and requesting that they pay that amount.
Petitioners failed to pay the amount owing.
On October 1, 2000, respondent mailed to petitioners a Final
Notice-–Notice of Intent to Levy and Notice of Your Right to a
Hearing with regard to their tax liabilities for 1996 and 1997.
On October 10, 2000, petitioners filed with respondent a Form
12153, Request for a Collection Due Process Hearing.
Petitioners’ request included a challenge to the validity of the
assessments and assertions that respondent failed to serve
petitioners with valid notices and demand for payment or valid
notices of deficiency.
By letter dated May 17, 2001, Appeals Officer Joe Gurnaby
provided petitioners with transcripts of their accounts for 1996
and 1997 reflecting the assessments described above. On August
31, 2001, Appeals Officer Gurnaby conducted an Appeals Office
hearing in this matter that petitioner Laura Schnitzler attended.
On October 4, 2001, respondent issued petitioners a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. The notice stated that the Appeals Office
determined that it was appropriate to proceed with the collection
of petitioners’ outstanding tax liabilities for 1996 and 1997.
On November 2, 2001, petitioners filed with the Court a joint
petition for lien or levy action seeking review of respondent’s
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Last modified: May 25, 2011