- 6 - of petitioners’ liability for 2000 to be $2,703,152.90. On November 13, 2003, the IRS sent petitioners a Notice of Federal Tax Lien for 2001. On December 4, 2003, petitioners filed a Request for a Collection Due Process Hearing for 2000 and 2001 in response to the Notice of Intent to Levy. On December 16, 2003, petitioners filed a Request for a Collection Due Process Hearing for 2000 and 2001 in response to the Notice of Federal Tax Lien. On April 8, 2004, petitioners filed a refund action for 2001 in the U.S. District Court for the Northern District of California. On July 6, 2004, the District Court action was dismissed for lack of subject matter jurisdiction. The dismissal was appealed to the U.S. Court of Appeals for the Ninth Circuit, but the appeal was dismissed on November 23, 2005. On April 9, 2004, the IRS notified petitioners that their amended return for 2000 was being audited. On May 13, 2004, respondent’s Appeals Office sent a Decision Letter Concerning Equivalent Hearing to petitioners regarding their tax liability for 2000. An equivalency hearing had been conducted because no request for a hearing was filed within the 30-day period prescribed by section 6320 and/or 6330 with respect to petitioners’ liability for 2000. In the decision letter, a Notice of Intent to Levy dated December 6, 2001, was not sustained because petitioners’ OIC was pending at the time thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007