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earn an income from 1999 to the present.
We also find that the joint liability is also the
responsibility of the spouse, who was involved in the
home and business with him. The failure to pay is also
her responsibility.
You also requested a written response to your calcula-
tion of the amounts due based on your submitted compu-
tations in a December 30, 2004 letter. I recall send-
ing you transcripts and explanation of the transcripts
on November 16, 2004 and wonder what else there can be
to submit. The computations per the transcripts were
found to be correct and I didn’t think there was a need
for further explanations.
After I found there were no likely abatements of penal-
ties, I asked that you submit any alternatives to the
levy action to me with financial statements. I cannot
consider any alternatives to the levy action without
financial statements. Without viable alternatives, I
have to sustain the levy action. [Reproduced liter-
ally.]
On April 26, 2005, respondent’s Appeals Office issued to
petitioner a notice of determination concerning collection
action(s) under section 6320 and/or 6330 (notice of determina-
tion). That notice stated in pertinent part:
Summary of Determination
You sent the Service a Letter of Protest subsequent to
a CP504 letter, Urgent letter, and subsequent to a
notice of intent to levy, LT 11. The Service Center
considered this a request for a hearing regarding the
notice of intent to levy and considered it timely.
You disagreed with the underlying liability and stated
that the Service owed you money.
We tried to hold a hearing with you and held a tele-
phone and correspondence hearing with your new repre-
sentatives. We wrote to you and explained the reasons
for the balances due for 1999.
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