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1998. (We shall refer to those assessed amounts, as well as
interest provided by law accrued after July 31, 2000, and August
28, 2000, respectively, as petitioners’ unpaid liability for each
of their taxable years 1997 and 1998.)
On July 31, 2000, and August 28, 2000, respectively, respon-
dent issued to petitioners notices of balance due with respect to
petitioners’ unpaid liabilities for their taxable years 1997 and
1998. On September 4, 2000, and October 2, 2000, respectively,
respondent issued additional notices of balance due with respect
to such unpaid liabilities.
On July 24, 2001, respondent issued to petitioners a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to their unpaid liability
for their taxable year 1998. On July 31, 2001, respondent issued
to petitioners a notice of Federal tax lien filing and your right
to a hearing (notice of tax lien) with respect to petitioners’
unpaid liability for each of their taxable years 1997 and 1998.
On or about August 30, 2001, in response to the notice of
intent to levy and the notice of tax lien, petitioners filed Form
12153, Request for a Collection Due Process Hearing (Form
12153),4 and requested a hearing with respondent’s Appeals Office
4Petitioner Shari Lee Wright Lyman (Ms. Lyman) did not sign
Form 12153 that petitioner G. Robert Lyman (Mr. Lyman) filed with
respondent. On Apr. 5, 2002, respondent accepted a ratification
of that form by Ms. Lyman.
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