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petitioner’s income for Federal taxes. Petitioners have declined
to adjust the amounts being withheld from their income or make
quarterly estimated tax payments. While the record is unclear as
to the exact amount that petitioners now owe in taxes, additions
to tax, and interest for all of the years from 1989 through 2001,
the parties agree that the total amount is in excess of $50,000.
In response to initial collection attempts, petitioners
submitted to respondent a statement of income and expenses. This
statement included a proposed installment agreement2 which called
for a $50 monthly payment to satisfy petitioners’ total
outstanding tax liability.3 On July 15, 2001, respondent mailed
to petitioners, via certified mail, a Final Notice--Notice of
Intent to Levy and Notice of Your Right to a Hearing, with
respect to petitioners’ 1999 tax liability. The notice reflected
an outstanding liability of $3,750.19 for that year. In response
to this notice, petitioners filed a Request for a Collection Due
Process Hearing. In this request, petitioners stated that they
disagreed with the levy notice because:
2While petitioners submitted a proposal for an installment
agreement, they declined to submit an offer-in-compromise in an
effort to settle their total tax liability. Petitioners declined
to do so in a letter which stated that petitioner “looked at the
offer in compromise [forms] and can see no reasonable offer to
pay off $49,100, plus the $3,293 we owe for 2001.”
3Nothing in the record suggests that petitioners have
offered a collection alternative with respect to 1999 apart from
the proposed installment agreement for their total tax liability.
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Last modified: May 25, 2011