George Ira Nicol - Page 5

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          year 1997 based on the return.  Prior to trial, the tax                     
          pertaining to the 1997 return was paid in full.  The Court                  
          dismissed the 1997 tax year from the petition.  Mrs. Nicol was              
          dismissed from the case because she had no involvement in the               
          1993 tax year which pertained solely to petitioner's individual             
          income tax liability.                                                       
          B.  Notice of Intent To Levy and Notice of Federal Lien                     
               The Nicols previously had an installment agreement in place            
          covering 1993 and 1997.  They stopped making the $50 monthly                
          payments under that agreement and respondent found them to be in            
          default.  Respondent sent petitioner a Notice of Intent to Levy             
          dated July 24, 2000.                                                        
               On October 19, 2000, respondent sent petitioner a Final                
          Notice, Notice of Intent to Levy, and Notice of Your Right to a             
          Hearing for unpaid taxes in the amount of $9,443.31 for 1993.               
          Subsequently, respondent filed a Notice of Federal Tax Lien on              
          May 24, 2001.                                                               
          C.  Appeals Office Hearing                                                  
               On June 8, 2001, Mrs. Nicol filed a Form 12153, Request for            
          a Collection Due Process Hearing (CDP Hearing), and attached a              
          Form 8379, Injured Spouse Claim and Allocation, for tax year                
          1997.  On that same date, petitioner also filed a Form 12153 for            
          tax year 1993.                                                              








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