126 T.C. No. 13
UNITED STATES TAX COURT
LOUIS A. AND CHRISTINE COX, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 21733-03L, 14693-04L. Filed May 3, 2006.
Ps’ 1999 and 2000 taxable years became the subject
of IRS collection activity through issuance of notices
of intent to levy. Appeals Officer S thereafter
conducted a simultaneous equivalent hearing with
respect to 1999 and collection hearing pursuant to sec.
6330, I.R.C., with respect to 2000. A principal focus
during that proceeding was the availability of
collection alternatives. The Appeals Office sustained
the proposed collection activity in November of 2003.
Meanwhile, Ps’ 2001 and 2002 taxable years had likewise
become the subject of a notice of intent to levy. Ps’
request for a hearing regarding these years was
assigned to S, who began his consideration thereof in
early 2004. Collection alternatives were again a
primary issue raised. Following a hearing with S, a
notice of determination sustaining the proposed levy
action was issued in July of 2004.
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