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petitioner Cathy A. Cooley’s tax liabilities.
On March 9, 2000, respondent issued to petitioners a Final
Notice of Intent to Levy and Notice of Your Right to A Hearing,
for their 1991 taxable year. The account summary in the final
notice indicated that respondent was trying to collect an
assessed balance of $2,493.93 and additional penalties and
interest of $1,084.03 for a total of $3,577.96.
On March 23, 2000, petitioners filed a Request for a
Collection Due Process Hearing, relating to the final notice for
their 1991 taxable year. In a letter attached to their request
for a section 6330 hearing, petitioners contended that the period
of limitations under section 6501(a) had expired, that respondent
had not issued them a notice of deficiency, and that the amount
of their tax liability had not been determined.
On July 5, 2000, petitioners petitioned this Court with
respect to the April 4, 2000, notice of deficiency. That case
was filed as docket No. 7464-00.
On August 8, 2000, petitioners were sent a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 for their 1989, 1990, 1992, 1993, and 1996 taxable
years. The notice of determination provided: “Our decision is
that the proposed levy action on 1989, 1990, 1992, 1993, and 1996
was appropriate.” The notice of determination further indicated
that “These outstanding balances owed are from your voluntarily
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