Phillip and Gladies Aaron - Page 5

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          later date”.  Petitioner did not believe that this course of                
          action would result in any problems.                                        
               The Internal Revenue Service (IRS) did not issue petitioners           
          a statutory notice of deficiency for 1997 or 1998.                          
          IRS Collection Efforts                                                      
               The IRS concluded that petitioners’ individual tax return              
          for 1997 contained multiple mathematical errors.  On June 10,               
          2000, after correcting the mathematical errors, the IRS assessed            
          a tax liability of $111,636.                                                
               The IRS concluded that petitioners’ individual tax return              
          for 1998 contained multiple mathematical errors.  On July 17,               
          2000, after correcting the mathematical errors, the IRS assessed            
          a tax liability of $34,890.                                                 
               Before collection proceedings, petitioner and Revenue                  
          Officer Steve Lerner corresponded regarding petitioners’ unpaid             
          taxes and refund claims for 1997 and 1998.                                  
               On November 16, 2000, Revenue Officer Lerner issued a Final            
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing.  On December 6, 2000, Revenue Officer Lerner advised               
          petitioners that he would delay filing the notice of Federal tax            
          lien until December 28, 2000, so that petitioners could file                
          amended income tax returns for 1997 and 1998.  On December 27,              
          2000, Revenue Officer Lerner issued a Notice of Federal Tax Lien            
          Filing and Your Right to a Hearing Under IRC 6320.                          






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