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On October 15, 2002, respondent’s Settlement Officer Richard
Stefanski conducted a telephone hearing with Mr. Haws with
respect to petitioners’ 1992 unpaid tax. In that hearing,
Mr. Haws argued that the 1992 joint tax liability could be no
greater than $1,455, the amount shown on the Form 433-D. Mr.
Haws further argued that the $1,455 liability had been fully
satisfied through various payments and overpayment credits.
Settlement Officer Stefanski reviewed the administrative file and
respondent’s transcripts of petitioners’ accounts and determined
that the balance due for 1992 was greater than $1,455.
On November 20, 2002, the Appeals Office issued Mr. Haws a
notice of determination sustaining the proposed levy for 1992.
The Appeals Office determined that the 1992 liability was due and
owing, that Mr. Haws had not shown or documented otherwise, and
that “Without payment in full or in installments, or other
resolution such as an offer in compromise or demonstration of
financial hardship, Appeals must sustain the proposed levy.”
Attached to the Notice of Determination is Settlement Officer
Stefanski’s memorandum, which states in pertinent part:
The current assessed balance due [for petitioners’ 1992
tax year] stands at $1,828.37, and the balance due
today, including penalty and interest accruals, stands
at $2,640.00.
Mr. Haws had previously entered into an installment
agreement during a collection due process (CDP) hearing
in 2001 in Boise, which included the 1992 period as
well as other periods for which liabilities existed:
1990, 1991, 1993, and 1994. Though 1992 was not one of
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