Ronald E. Boyer - Page 5

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               On August 31, 2001, respondent sent the Boyers a Notice of             
          Intent to Levy under Section 6331(d) relating to their unpaid               
          1986 and 1987 tax liabilities.  The Boyers timely filed Form                
          12153, Request for a Collection Due Process Hearing.  In their              
          request, the Boyers raised two issues.  First, the Boyers                   
          contended that they had no outstanding tax liability for 1986 or            
          1987 because the RFTL showed that their outstanding tax liability           
          was either paid or made unenforceable.  Second, the Boyers                  
          contended that the statutory period for collection had expired              
          for both the 1986 and 1987 tax liabilities.  The Boyers did not             
          raise any spousal defenses or offer collection alternatives.                
               An Appeals officer wrote a letter to the Boyers dated                  
          March 7, 2002, and explained that, although the transcripts of              
          their account showed that the lien for 1986 was released as                 
          reflected by the RFTL, the lien for 1986 was released                       
          prematurely.  The Appeals officer further explained that the 1986           
          liability remained due and owing because the Boyers failed to               
          make all required payments under the 1986 installment agreement.            
          The Appeals officer also noted that the RFTL related solely to              
          the 1986 liability, not the 1987 liability.  As with the 1986               
          liability, the balance of the 1987 liability remained due and               
          owing.                                                                      
               Regarding the Boyers’ argument that the collection period              
          had expired, the Appeals officer reminded the Boyers that they              






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