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apply to the 1988 deficiency; therefore, the sole issue for
decision is whether the collection by respondent of the second
mortgage should have been applied to petitioners’ 1988 tax
liability.
On February 27, 2001, respondent notified petitioners of an
intent to levy with respect to petitioners’ unpaid tax
liabilities for 1988, 1992, 1993, and 1997. The notice listed
the following amounts due:
Year Amount
1988 $6,824.33
1992 548.28
1993 2,701.54
1997 2,178.67
Petitioners filed a timely Form 12153, Request for a
Collection Due Process Hearing. In their request, petitioners
stated their belief that the tax liabilities for the subject
years had been overpaid and “over the past nine years concerning
these matters” they had “never had a hearing concerning moneys
paid [the IRS] in excess of what I owed.” Petitioners thereafter
received a letter from an Appeals officer that included
transcripts of petitioners’ accounts showing assessments and
payments made. Petitioners were also asked to provide
documentation, such as canceled checks, to show payments not
applied to their accounts. Petitioners were also asked to
provide financial information regarding possible collection
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