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On April 17, 2003, respondent sent to petitioners a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
(final notice). Respondent sent the final notice to petitioners
at the Lake Forest address.
On May 5, 2003, petitioners filed with respondent a Form
12153, Request for a Collection Due Process Hearing. On the Form
12153, petitioners listed the Lake Forest address as their
address.
The only issue raised by petitioners in the Form 12153 was a
challenge to the existence or amount of the underlying liability.
During the course of the administrative phase of this case,
respondent’s Appeals Office in Kansas City, Missouri,
corresponded with petitioners at the Lake Forest address. The
Appeals Office also conducted a face-to-face hearing attended by
petitioner James L. Geary. The only issue raised by petitioners
before the Appeals Office was a challenge to the existence or
amount of the underlying liability.
On June 3, 2004, respondent’s Appeals Office sent to
petitioners a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (notice of
determination). The Appeals Office sent the notice of
determination to petitioners at the Lake Forest address.
In the notice of determination, the Appeals Office sustained
the levy action.
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Last modified: May 25, 2011