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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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