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On March 8, 2003, respondent issued to petitioner a Final
Notice of Intent To Levy and Notice of Your Right To A Hearing,
with respect to the 2001 liability.4 The notice listed a total
amount due, including statutory additions, of $5,410.37.
In response to the notice, petitioner and Mr. Picchiottino
timely submitted a Form 12153, Request for a Collection Due
Process Hearing, dated March 10, 2003. The Form 12153 was filed
with the Internal Revenue Service (IRS) on or before March 27,
2003. The form pertained to 20015 and contained the following
statement of disagreement with the proposed collection action:
“TOLD STATUS WAS ‘UNCOLLECTABLE’ by IRS Mrs. Hernandez #8903695”.
On March 13, 2003, a Notice of Federal Tax Lien Filing and
Your Right to a Hearing was issued to petitioner with respect to
2001. Although petitioner and Mr. Picchiottino had checked boxes
on the filed Form 12153 dated March 10, 2003, discussed above,
indicating disagreement with both a filed notice of Federal tax
lien and a notice of levy, that Form 12153 was signed and sent by
petitioner and Mr. Picchiottino before the notice of lien was
4 Respondent issued to Mr. Picchiottino an identical Final
Notice of Intent To Levy and Notice of Your Right to a Hearing
with respect to the 2001 year.
5 This Form 12153 also listed 2002, but no collection
activity is reflected by the record with respect thereto.
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Last modified: May 25, 2011