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additional notices requesting that they pay the balance due for
1997. Although petitioners wrote to respondent acknowledging
receipt of each of the above-described notices, petitioners
failed to pay the amount owing.
C. Respondent’s Final Notice and Petitioners’ Response
On October 12, 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 tax liability for 1997.
On November 9, 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 Federal income taxes.
Petitioners also asserted that they were challenging the amount
of tax listed as due in the Final Notice on the grounds that they
did not receive a valid notice and demand for payment or a valid
notice of deficiency for 1997.
D. The Appeals Office Hearing
Prior to an Appeals Office hearing, Appeals Officer Richard
J. Sigler (the Appeals officer) provided petitioners with a
transcript of their account for 1997. The record in this case
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