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to do so. Accordingly, on March 27, 2000, respondent assessed
the determined deficiency and accuracy-related penalty, as well
as statutory interest. On that same day, respondent sent
petitioners a notice of balance due, informing petitioners that
they had a liability for 1997 and requesting that they pay it.
Petitioners failed to do so.
On May 1, 2000, respondent sent petitioners a second
notice of balance due for 1997. Once again, petitioners failed
to pay the amount owing.
C. Respondent’s Final Notice and Petitioners’ Response
On August 31, 2000, respondent sent petitioners a Final
Notice-–Notice of Intent to Levy and Notice of Your Right to a
Hearing (the Final Notice). The Final Notice was issued in
respect of petitioners’ outstanding liability for 1997.
On September 14, 2000, petitioners submitted to respondent a
Form 12153, Request for a Collection Due Process Hearing.
Petitioners requested that the Appeals Office demonstrate that
petitioners are required to pay the amount listed as due in the
Final Notice.
5(...continued)
if I wanted to “contest this deficiency before making
payment,” I must “file a petition with the United
States Tax Court.”
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Last modified: May 25, 2011