Arthur W. & Rita C. Miller - Page 4

                                        - 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 a                






Page:  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