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Individuals, Estates and Trusts) of $104,316. The return was not
accompanied by payment.
The Internal Revenue Service (IRS) assessed the reported
amounts for 1999, as well as further additions to tax and
interest, on November 11, 2000, and sent petitioners a notice of
balance due. Petitioners apparently entered into an installment
agreement in December of 2000 and made a number of payments, but
an assessed balance remained at the termination of the agreement.
On March 14, 2002, a Final Notice - Notice of Intent to Levy and
Notice of Your Right to a Hearing, was issued to petitioners for
1999.
Petitioners filed a joint Form 1040 for 2000 on April 12,
2002. They reported adjusted gross income of $442,932, taxable
income of $381,450, total tax of $145,393, no payments, and an
amount owed (with addition as in 1999) of $151,954. Again no
payment accompanied the return. Assessment of the reported
amounts, along with additions to tax and interest, was made on
May 20, 2002, and a notice of balance due was sent on that date.
On October 31, 2002, the IRS issued to petitioners a Final
Notice - Notice of Intent To Levy and Notice of Your Right to a
Hearing, with respect to their 2000 liability. On November 27,
2002, petitioners’ representative, Theodore H. Merriam
(Mr. Merriam) submitted to the IRS two Forms 12153, Request for a
Collection Due Process Hearing, one pertaining to 1999 and the
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