- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008