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On November 26, 2002, the settlement officer who conducted
the administrative hearing sent petitioners a letter inviting
petitioners to discuss an installment agreement. Thereafter,
petitioner twice informed the settlement officer that he would
provide additional financial information in connection with an
installment agreement, but petitioner never did so.
On January 10, 2003, respondent issued to petitioners a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. In the notice of determination,
respondent determined, in pertinent part: (1) The filing of the
tax lien notice was sustained because the 1994 tax liability
remained unpaid; (2) the notice of intent to levy was sustained
because respondent could not reach an installment agreement with
petitioners, and (3) all applicable laws and administrative
procedures had been satisfied.
On August 12, 2003, respondent filed a motion for summary
judgment. On November 3, 2003, the motion was denied and the
case was remanded to respondent’s Appeals Office for
reconsideration regarding whether petitioners had fully paid
their 1994 tax liability.
On November 20, 2003, respondent revoked the release of the
tax lien notice. In December 2003, respondent’s settlement
officer offered petitioners the opportunity for a further
administrative hearing, but petitioners did not respond. On
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Last modified: May 25, 2011