- 4 - The parties settled the 1996 case and, on March 13, 1997, the Court entered a decision pursuant to the parties’ stipulated agreement that petitioners had a $2,931 deficiency and no “addition to tax” under section 6662(a). On May 19, 1997, respondent assessed this $2,931 deficiency and sent to petitioners a notice and demand for $21,164. On September 20, 2000, respondent sent to petitioners a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing relating to 1993. On October 17, 2000, petitioners filed Form 12153, Request for a Collection Due Process Hearing. On June 28, 2001, respondent mailed to petitioners a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On July 31, 2001, petitioners filed their petition in the instant case. On August 7, 2001, petitioners filed an amended petition. On September 6, 2001, respondent filed the answer to this amended petition. This answer was signed by Ann M. Welhaf (hereinafter sometimes referred to as Welhaf), Acting Associate Area Counsel, and dated September 5, 2001. Welhaf also prepared a memorandum dated September 5, 2001, addressed to: Assistant Chief Counsel, Procedure and Administration, Collection Bankruptcy and Summons, Attn: Alan Levine, Chief Branch 1, CBS.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007