Donald R. Cooley and Cathy A. Cooley - Page 11

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         filed tax returns Form 1040 and Form 1040X.”  Additionally, the              
         notice of determination indicated that:  “The Service has already            
         considered and issued a separate determination letter on the                 
         Innocent Spouse issue.”                                                      
               Attachment 3193, attached to the notice of determination,              
         provided:                                                                    
               Issues Relating to the Unpaid Liabilities:                             
               The unpaid liabilities shown on the Notice of Intent to                
               Levy (L-1058/LT-11) dated 06/27/1999 are from                          
               voluntarily filed original tax returns, Form 1040, or                  
               amended returns, Form 1040X.                                           
               •    Review of your account for the years 1989, 1990, 1992,            
                    and 1993 shows that the outstanding balances owed were            
                    for accrued interest on your amended returns.                     
               •    Review of your account for the 1996 year shows that the           
                    outstanding balance owed included some of your original           
                    tax liability, penalty, and accrued interest.                     
                         *    *    *    *    *    *    *                              
               The Notice of Intent to Levy dated 6/27/1999 did not                   
               include and [sic] amounts from the pending audit                       
               adjustments for 1989, 1990, 1992, or 1993.  The                        
               proposed audit adjustments were considered separately                  
               by the Appeals office.  A separate Statutory Notice of                 
               Deficiency was issued by the Appeals Office on April 4,                
               2000, and gave you the right to petition to the Tax                    
               Court.  Those issues are not part of this Collection                   
               Due Process Hearing.  Your claim for Innocent Spouse                   
               relief has also been considered separately by the                      
               Appeals Office and a separate determination letter was                 
               issued.  That issue is not part of this Collection Due                 
               Process hearing.                                                       
               Respondent’s Appeals officer issued a statement in support             
         of the notice of determination for petitioners’ 1989, 1990, 1992,            








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