-4-
self-employment income. In 1991 and 1992, respondent assessed
petitioners’ Federal income tax liabilities for 1986 and 1991,
respectively.
On June 25, 1993, petitioners filed for bankruptcy under
chapter 13 of the Bankruptcy Code in the Southern District of
Ohio, Western Division. The IRS filed a proof of claim in the
case on or about September 8, 1993, and an amended proof of claim
approximately 3 months later. Petitioners raised no objection to
the IRS’s claims. On separate occasions between 1994 and 1998,
respondent assessed petitioners’ Federal income tax liability for
1992 through 1997.
On January 5, 1999, the bankruptcy court entered an order
granting a requested modification of the plan concerning the
IRS’s claims. The modification stated that any tax liability not
fully paid under the plan would survive discharge. The
bankruptcy court issued petitioners a discharge on February 25,
1999, and closed the case on March 5, 1999. Afterwards,
respondent proposed a levy to collect the subject years’
surviving tax liabilities, and petitioners challenged the amounts
that respondent asserted were due.
On May 9, 2001, respondent sent petitioners a Letter 1058,
Notice of Intent to Levy and Your Right to a Due Process Hearing,
as to the subject years. Petitioners requested the referenced
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