-4-
certain Schedule C, Profit or Loss From Business, expenses,
totaling $8,063.
On July 18, 2003, Ms. Kuykendall called respondent’s
examiner regarding a letter she had received related to
petitioners’ 2000 tax year. During the conversation, Ms.
Kuykendall was informed that a notice of deficiency for 1999 had
been mailed to them. Ms. Kuykendall informed respondent that
petitioners had moved and that they did not receive the notice of
deficiency. At Ms. Kuykendall’s request, the examiner faxed a
copy of the notice of deficiency to petitioners that day. With
respect to the notice of deficiency, petitioners did not file a
petition with this Court.
On February 14, 2004, respondent sent petitioners a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
for 1999. On March 7, 2004, petitioners submitted a Form 12153,
Request for a Collection Due Process Hearing. In their request
for relief, petitioners disputed the underlying tax liability by
asserting that the disallowed business expenses were valid. They
also disputed the examiner’s decision not to postpone the
examination. On May 6, 2004, respondent’s Appeals Office sent a
letter to petitioners, offering them a hearing. On May 19, 2004,
Ms. Kuykendall sent a letter to respondent’s Appeals Office,
accompanied by several documents relating to the disallowed
business deductions.
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