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1994, respondent sent petitioners a notice of balance due,
informing them that they had a liability for 1993 and requesting
that they pay it. Petitioners have made no payments to their
account for 1993.
C. Collection-related Matters at the Administrative Level
On December 17, 2001, respondent sent petitioners a Final
Notice/Notice Of Intent To Levy And Notice Of Your Right To A
Hearing in respect of their outstanding tax liabilities for 1992
and 1993.
On January 10, 2002, petitioners filed with respondent Form
12153, Request for a Collection Due Process Hearing. The request
stated only that “I have never recieved [sic] notice of this
tax”.
On July 10, 2002, an administrative hearing was conducted by
respondent’s Appeals Office in Atlanta, Georgia. At the
administrative hearing, petitioners repeated their assertion that
they had not received any notice that there was tax due for
either 1992 or 1993. Petitioners also stated that they did not
have any income tax liability for either of those years.
Also discussed at the administrative hearing was an
installment agreement. Such collection alternative did not prove
to be feasible, however, because (as explained by the Appeals
officer in his Case Memo) petitioners “[reserved] the right to
dispute the tax for the 1992 and 1993 tax year[s].”
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