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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 a
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Last modified: May 25, 2011