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not less than 30 days before the day of the first levy with
respect to the amount of the unpaid tax for the taxable
period.
(3) Information Included With Notice.-–The notice
required under paragraph (1) shall include in simple and
nontechnical terms–
(A) the amount of unpaid tax;
(B) the right of the person to request a hearing
during the 30-day period under paragraph (2); and
* * * * * * *
(b) Right To Fair Hearing.–
(1) In General.-–If the person requests a hearing under
subsection (a)(3)(B), such hearing shall be held by the
Internal Revenue Service Office of Appeals.
(2) One Hearing Per Period.-–A person shall be entitled
to only one hearing under this section with respect to the
taxable period to which the unpaid tax specified in
subsection (a)(3)(A) relates.
On February 3, 1999, respondent sent to petitioners a Notice
of Intent To Levy And Notice Of Your Right To A Hearing (notice
of intent to levy) with respect to the taxable years 1991, 1992,
1994, and 1995. On February 24, 1999, the Internal Revenue
Service (IRS) received petitioners’ February 22, 1999, Request
for a Collection Due Process Hearing with respect to those years.
On March 8, 1999, A.G. Wilson (Mr. Wilson), an Appeals officer,
sent a letter to petitioners which states as follows:
This case has been referred to our office.
I will write or call you soon to arrange a mutually
satisfactory date for a conference.
If you need to contact me in the meantime, you may
write me at the address below or call me at the telephone
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Last modified: May 25, 2011