Michael V. Severo and Georgina C. Severo - Page 5




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          request an Appeals Office collection hearing relating to the levy           
          on petitioners’ California income tax refund, but petitioners did           
          not request a hearing.                                                      
               Over the years, petitioners apparently made substantial                
          payments on their 1990 Federal income taxes, but petitioners’               
          payments have not fully satisfied petitioners’ 1990 Federal                 
          income taxes.2                                                              
               On September 7, 2005, respondent mailed to petitioners a               
          notice of intent to make a second levy on petitioners’ property             
          relating to petitioners’ outstanding 1990 Federal income taxes,             
          and on September 8, 2005, respondent mailed to petitioners an               
          NFTL.  Respondent’s notice of intent to make a second levy on               
          petitioners’ property did not give petitioners another right to             
          request an Appeals Office collection hearing relating to                    
          respondent’s second levy.  Respondent’s NFTL explained                      
          petitioners’ right to request an Appeals Office collection                  
          hearing relating to the tax lien filing.                                    
               On or about September 15, 2005, petitioners requested an               
          Appeals Office hearing relating both to respondent’s September 7,           
          2005, second levy notice and to respondent’s September 8, 2005,             
          NFTL.                                                                       



               2 The record herein does not indicate the exact amount still           
          outstanding on petitioners’ 1990 Federal income taxes.                      






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