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the amount due by January 17, 2000. On January 9, 2000,
petitioners wrote a letter to respondent challenging respondent’s
December 27, 1999, letter as a “bootleg, fraudulent document”.
On July 22, 2000, respondent mailed to petitioners a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing.
The notice stated that petitioners owed taxes and statutory
additions totaling $3,738.23 for 1997, and that respondent was
preparing to collect the amount due by levy.
Petitioners filed with respondent a Request for a Collection
Due Process Hearing that included allegations that respondent was
barred from proceeding with collection because petitioners were
not served with a valid notice of deficiency or notice and demand
for payment. Petitioners also challenged the validity of the
underlying assessment and requested that respondent provide them
with a copy of a summary record of assessment.
On May 9, 2001, the Appeals Office issued a letter to
petitioners informing them that their administrative hearing was
scheduled for June 11, 2001. Along with the letter, the Appeals
Office provided petitioners with a transcript of their account
for 1997 that showed that a credit was posted to petitioners’
account for withheld taxes of $7,335.18 on April 15, 1998. The
transcript of account also showed that petitioners filed their
1997 tax return reporting a tax liability of zero on September 7,
1998, and three assessments were entered against petitioners for
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Last modified: May 25, 2011