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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 that
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