- 4 - petitioner a notice of intent to levy with respect to petition- ers’ taxable year 2001. Respondent received a signed receipt from each petitioner indicating that each petitioner received the notice of intent to levy with respect to petitioners’ taxable year 2000 and the notice of intent to levy with respect to petitioners’ taxable year 2001. On September 14, 2004, in response to the respective notices of intent to levy with respect to petitioners’ taxable years 2000 and 2001, petitioners filed an offer-in-compromise with respon- dent. Petitioners did not file Form 12153, Request for a Collec- tion Due Process Hearing (Form 12153), with respondent in re- sponse to those respective notices. Nor did petitioners submit any other documents to respondent that could be construed as a request for a hearing with respondent’s Appeals Office (Appeals Office) with respect to the respective notices of intent to levy relating to petitioners’ taxable years 2000 and 2001. On September 24, 2004, respondent rejected the offer-in- compromise filed by petitioners with respect to petitioners’ taxable years 2000 and 2001. On October 28, 2004, respondent filed a notice of Federal tax lien with respect to petitioners’ taxable years 2000 and 2001. On November 4, 2004, respondent issued to petitioners aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011