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notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to their taxable year
1996 and a separate notice of intent to levy with respect to
their taxable years 1997 and 1999.
On or about July 20, 2002, in response to the notice of
intent to levy with respect to their taxable year 1996,
petitioners filed Form 12153, Request for a Collection Due
Process Hearing (Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office). On the same date,
in response to the notice of intent to levy with respect to their
taxable years 1997 and 1999, petitioners filed Form 12153 and
requested a hearing with the Appeals Office. Petitioners
attached, inter alia, a document to their Form 12153 with respect
to their taxable year 1996 (petitioners’ attachment to their 1996
Form 12153) and a document to their Form 12153 with respect to
their taxable years 1997 and 1999 (petitioners’ attachment to
their 1997 and 1999 Form 12153). Petitioners’ attachment to
their 1996 Form 12153 and petitioners’ attachment to their 1997
and 1999 Form 12153 were identical and set forth, inter alia, the
same types of statements, contentions, arguments, requests, and
questions that petitioners set forth in petitioners’ attachment
to their 1996 Form 1040 and petitioners’ attachment to their 1997
Form 1040A. In addition, petitioners’ attachment to their 1996
Form 12153 and petitioners’ attachment to their 1997 and 1999
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Last modified: May 25, 2011