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A. Notices of Determination for the Taxable Years 1997, 1998,
and 1999
1. Final Notices of Intent To Levy
On June 26 and May 16, 2000, respectively, respondent
issued to petitioners Forms 1058, Final Notices of Intent to Levy
and Notice of Your Right to a Hearing, as required by section
6330(a), with respect to unpaid liabilities for the taxable years
1997 and 1998. On September 28, 2000, respondent issued to
petitioners Form 1058 for the taxable year 1999.
On October 12, 2000, petitioners submitted Form 12153,
Request for a Collection Due Process Hearing, in response to the
May, June, and September final notices of intent to levy,
requesting a hearing for the taxable years 1997-99. Petitioners’
Form 12153 was timely submitted in response to the September 2000
notice of intent to levy for the taxable year 1999. However,
petitioners’ request for a hearing under section 6330 for the
taxable years 1997 and 1998 was untimely submitted. Accordingly,
respondent provided an “equivalent” hearing under section
301.6330-1(i), Proced. & Admin. Regs., as to the proposed levy
for the taxable years 1997 and 1998. In addition, petitioners
filed Form 2848, Power of Attorney and Declaration of
Representative, conferring on their C.P.A., Robert Kristel, the
authority to represent petitioners at their hearing for the
taxable years 1997-99.
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