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Determination).1 Petitioners allege that they have insufficient
assets to pay their income tax liability for the year 2000.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners resided in Lewisville, Texas.
On August 20, 2003, respondent mailed to each of the
petitioners, individually, a Final Notice of Intent to Levy and
Notice of Your Right to a Hearing. By letter dated September 16,
2003, petitioners’ attorney mailed to respondent two Forms 12153,
Request for a Collection Due Process Hearing, one for each
petitioner, which stated that petitioners “have insufficient
income and assets to full pay the outstanding tax liabilities for
2000, [and] they would like to propose either an Installment
Payment Agreement or an Offer in Compromise.”
On October 6, 2003, respondent’s Collection Division
contacted petitioners’ attorney by telephone concerning the
Requests for a Collection Due Process Hearing (section 6330
hearing). On December 12, 2003, respondent’s Appeals Office in
Dallas, Texas, wrote petitioners’ attorney concerning the
requests for a section 6330 hearing asking that petitioners
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011