- 4 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011