Homer W. and Nancy L. Winans - Page 7

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          Florida, to foreclose a mortgage.  Petitioners filed an answer              
          and counterclaim to Countrywide’s complaint.                                
               The issue for decision is whether respondent correctly                 
          determined to proceed with collection of petitioners’ tax for               
          A.   Petitioners’ Contentions                                               
               Petitioners contend that respondent’s determinations to                
          proceed with collection should be overturned on the grounds that:           
          (1) They never received valid notices of deficiency; (2) no                 
          section of the Internal Revenue Code makes them liable for                  
          Federal income taxes; (3) respondent failed to give them a notice           
          and demand for payment of the taxes in question; (4) respondent             
          failed to give them verification that all applicable laws and               
          administrative procedures were followed in this matter; and (5)             
          collection of the taxes in question would impose an undue                   
          hardship on them.                                                           
          B.   Discussion                                                             
               1. Whether Petitioners Received Valid Notices of                       
               Although petitioners stipulated that they received notices             
          of deficiency for 1996-2001, they contend that the notices were             
          invalid.  Petitioners contend that they were improperly precluded           
          from challenging their underlying tax liability for tax years               
          1996-2001.  They base this contention on their claim that the               
          notices of deficiency they received were not valid because the              

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