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collection actions in question. He invited petitioners to
request a date and time for a hearing.
Although petitioner informed the Appeals Office that he
would write to schedule a hearing, he did not do so. Respondent
offered petitioners several opportunities to propose collection
alternatives or to provide other information. Petitioners did
not do so.
E. Respondent’s Notice of Determination
On July 6, 2004, respondent’s Appeals Office sent to
petitioners a joint Notice of Determination Concerning Collection
Action(s) for 1999. In the notice, the Appeals Office determined
that the lien for 1999 was properly filed and that respondent may
proceed to collect petitioners’ unpaid tax for 1999 by levy. On
July 8, 2004, respondent’s Appeals Office sent to petitioner a
Notice of Determination Concerning Collection Action(s) for the
years 1996, 1997, 1998, 2000, and 2001. In the notice, the
Appeals Office determined that the liens for each of those years
were properly filed and that respondent may proceed to collect
petitioner’s unpaid taxes for 2000 and 2001 by levy. Petitioners
filed timely petitions challenging the notices described above.
F. Mortgage Foreclosure
On January 20, 2005, Countrywide Home Loans, Inc.
(Countrywide) filed a complaint against petitioners in the
Circuit Court of the 7th Judicial Circuit for Flagler County,
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Last modified: May 25, 2011