James L. Geary and Carol O. Geary - Page 5

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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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