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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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Last modified: March 27, 2008