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years. Petitioners made payments from November 2000 until
September 2003. On December 6, 2000, the revenue agent rejected
petitioners’ proposed January 2000 installment agreement and
referred the case to the Appeals Office to fulfill petitioners’
request for a hearing. In their Form 12153, petitioners again
requested an installment agreement and claimed that the monthly
payments previously determined by the revenue agent exceeded
their ability to pay.
The Appeals officer engaged in a series of phone calls and
letters with petitioners’ representative concluding sometime in
November 2001. On July 12, 2001, the Appeals officer mailed to
petitioners a letter offering them the opportunity to have a
face-to-face conference on July 25, 2001, for the taxable years
1997-99. At petitioners’ representative’s request, the Appeals
officer rescheduled the conference for September 12, 2001, at the
Appeals Office. Neither petitioners nor their representative
appeared for the September 12, 2001, conference. On November 9,
2001, respondent mailed to petitioners a followup letter giving
them 2 weeks to raise any additional issues regarding the lien or
intent to levy. Petitioners’ representative then contacted the
Appeals officer and, on behalf of petitioners, proposed an
installment agreement requiring monthly payments of $800 over 5
years to pay their outstanding tax liability of $55,362.13, which
terms were the same terms the revenue agent in charge of
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Last modified: May 25, 2011