Thomas J. and Bonnie F. Ratke - Page 4




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               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.            












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