G. Robert Lyman and Shari Lee Wright Lyman - Page 4




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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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