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decision is whether the Appeals Office determination to proceed
with a proposed levy should be sustained.
Background
When petitioners filed their petition, they resided in
Boise, Idaho. Petitioners are married and for all relevant years
filed joint Federal income tax returns.
On October 24, 1999, petitioners filed an untimely 1992
joint Federal income tax return. They reported a $3,049.65 tax
liability but did not include payment with their return.
On December 20, 1999, respondent assessed petitioners’
reported 1992 tax liability (after allowing them a $452 earned
income credit), plus a $584.47 addition to tax for late filing of
their 1992 return, a $593.75 addition to tax for failing to pay
tax, and $2,337.15 interest. On that same date, respondent
issued to petitioners a statutory notice of balance due.
Petitioners also failed to pay taxes for their 1991, 1993,
and 1994 tax years. The unpaid taxes for these years were the
subject of a prior collection proceeding, culminating in a
section 6330 Appeals Office hearing that occurred sometime in
early 2000. On June 1, 2000, petitioners signed a Form 433-D,
Installment Agreement (the installment agreement), prepared by
Appeals Officer Bob Baker. The installment agreement states that
it covers the tax years 1991, 1993, and 1994. Notwithstanding
this statement, petitioners believed, on the basis of their
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