- 5 - Of Intent To Levy And Notice Of Your Right To A Hearing concerning petitioners’ unpaid liability. On July 29, 2002, petitioners timely filed with respondent Form 12153, Request for a Collection Due Process Hearing. On May 13, 2003, Mr. Rehberg attended an administrative hearing conducted at respondent’s Appeals Office in Seattle, Washington. Throughout petitioners’ Appeals consideration, the parties exchanged substantial correspondence concerning petitioners’ distressed financial situation and collection alternatives. On August 28, 2003, the Appeals Office sent petitioners a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330 (notice of determination) concerning petitioners’ unpaid liability. In the notice of determination, the Appeals Office stated that respondent’s determination to proceed with collection by way of levy should be sustained. On October 1, 2003, petitioners filed a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d) challenging respondent’s determination.10 In the petition, petitioners state: Liability is for capital gains taxes on our primary residence. -Asking for relief under 1997 law for one time exclusion of capital gains tax for sale of residence. 10 The petition was timely mailed to the Court on Sept. 26, 2003. Secs. 6330(d), 7502(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011