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Taxable Year Unpaid Balance of Assessment
1994 $ 9,850.51
1995 11,938.14
1998 1,568.62
(We shall refer to the foregoing unpaid balance of assessment for
each of petitioners’ taxable years 1994, 1995, and 1998, as well
as any accrued interest thereon not yet assessed, as petitioners’
unpaid liability for each of those years.)
On January 31, 2001, respondent mailed to petitioners a
notice informing them that respondent had filed a Federal tax
lien with respect to petitioners’ unpaid liability for each of
their taxable years 1994, 1995, and 1998 and that they had a
right to a hearing (Appeals Office hearing) with respect to that
lien.
On February 8, 2001, petitioners filed Form 12153, Request
for a Collection Due Process Hearing (Form 12153). In an attach-
ment to Form 12153, petitioners stated in pertinent part:
First, may we state for the record that your intent to
enact a lien against any assets, jobs, or personal
property or finances that we may have is a grave error.
We insist that you cease from any impending actions to
avert any embarrassment or possible legal consequences,
which can thus be avoided. We trust that you will fax
us a statement immediately of your intent to suspend
action as outlined in your (collection appeals rights).
Second, we are eager to finally put closure to this
outstanding tax matter for the years indicated, and we
trust that you will work fairly and cooperatively with
us in reaching a mutual resolution. We feel our posi-
tion of not owing the outstanding balance for which
payment is being requested is based on the bankruptcy
court decree under case number (98-43339) AJG, dated
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Last modified: May 25, 2011