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On May 29, 2002, respondent mailed to petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice). On June 28, 2002, petitioners elected to
exercise their right under section 6330 to a hearing with
respondent’s Office of Appeals. Petitioners attached to the form
an explanation of their disagreement with the proposed levy,
stating:
Taxpayers Joseph DelVecchio and Carol DelVecchio
do challenge the IRS Final Notice of Intent to Levy
based on the fact that the federal statutes cited in
the Notice as authorizing the actions in the Notice do
not grant the legal authority for the IRS to Levy any
assets of the two taxpayers named in each of the two
Notices.
Additionally, petitioner Carol DelVecchio claimed relief
from joint liability under section 6015 as to the liability
underlying both the lien and levy.
Both petitioners elected correspondence hearings. On
October 1, 2002, respondent faxed Carol DelVecchio’s certified
transcripts of assessments to her attorney. On November 5, 2002,
respondent sent a letter to Joseph DelVecchio outlining
respondent’s position and attaching Joseph DelVecchio’s certified
transcripts of assessments.
Extensive correspondence was exchanged between respondent
and both petitioners, culminating in a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
for 1987 and 1988 mailed on April 16, 2003. This notice
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Last modified: May 25, 2011