Myong Soo Kim and Sung Me Hwang - Page 2

                                         -2-                                          
                                  FINDINGS OF FACT                                    
               Petitioners resided in Olympia, Washington, when the                   
          petition in this case was filed.                                            
               On February 4, 2002, respondent issued a Final Notice--                
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          (the NIL) to petitioner Myong Soo Kim (Mr. Kim) with respect to             
          his Federal income tax liability for 1997, and a separate NIL to            
          Mr. Kim and Sung Me Hwang (Ms. Hwang) with respect to their                 
          Federal income tax liability for 1999.  The NILs informed                   
          petitioners of respondent’s intent to levy upon their property              
          pursuant to section 6331 and of their right to a hearing with the           
          Internal Revenue Service’s (IRS) Office of Appeals (Appeals)                
          under section 6330.  In response, petitioners submitted two Forms           
          12153, Request For a Collection Due Process Hearing (hereinafter            
          section 6330 hearing), one for 1997 and one for 1999, each                  
          postmarked March 14, 2002.  Respondent received the Forms 12153             
          on March 18, 2002.                                                          
               On July 29, 2002, Appeals Officer Geraldine H. Melick                  
          (Appeals Officer Melick) was assigned to petitioners’ case.  By             
          letter dated July 30, 2002, Appeals Officer Melick informed                 
          petitioners that their section 6330 hearing requests were not               


               1(...continued)                                                        
          the Internal Revenue Code in effect at the time the petition in             
          this case was filed, and all Rule references are to the Tax Court           
          Rules of Practice and Procedure.                                            




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