Michael D. Cornwell and Hilary J. Iker - Page 7

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               After reviewing the correspondence, Lin made a determination           
          to permit the collection action to proceed.  On June 26, 2006, he           
          sent three separate Appeals Case Memorandums, delineating the               
          facts and reasons underlying his decision, for managerial                   
          approval.  As of that time, petitioners owed approximately                  
          $84,000 for the years in issue.                                             
               After managerial approval, the Appeals Case Memorandums were           
          incorporated into three separate notices of determination:                  
          (1) Notice of determination for levy for 2002 taxes dated July 7,           
          2006; (2) notice of determination for lien for 1997 through 2002            
          taxes dated July 14, 2006; and (3) notice of determination for              
          lien for 1994 through 1996 taxes dated July 14, 2006.                       
               After Lin’s June 26, 2006, Appeals Case Memorandums and                
          prior to the issuance of the notices of determination, petitioner           
          sent two faxes to Lin.  Each fax attached a copy of an email                
          dated July 5, 2006, referring to overtime at the law firm where             
          petitioner was employed.  The email stated:                                 
               After assessing the current work load in the firm, it                  
               has been determined that no overtime is necessary at                   
               this time for support staff.                                           
               If something changes in your work load which would                     
               require a necessity for overtime, you will need to have                
               approval from your supervisor in advance.                              
               Petitioners invoke our jurisdiction under section 6330(d) to           
          review the three notices of determination described above.  (The            

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