Rainer B. and Sonja D. Wagner - Page 6

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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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