John E. and Sandra L. West - Page 5




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          late filing and late payment additions to tax and penalties that            
          respondent had assessed against petitioners relating to                     
          petitioners’ 2000, 2001, and 2002 Federal income tax returns and            
          warning petitioners of the potential for default on the OIC that            
          had been entered into if petitioners did not pay the various                
          additions to tax and penalties that had been assessed against               
          them.                                                                       
               Specifically, in November 2003, respondent mailed to                   
          petitioners at their Via Chirpia, Mission Viejo, address a notice           
          alerting petitioners that the OIC was subject to likely                     
          termination if petitioners’ outstanding additions to tax and                
          penalties for 2001 and 2002 were not paid.                                  
               In January 2004, respondent mailed to petitioners (at the              
          Via Chirpia, Mission Viejo, address) a notice of default on the             
          OIC, informing petitioners that the OIC was terminated.                     
               On June 18, 2005, respondent mailed to petitioners a notice            
          of intent to levy and a notice of petitioners’ right to a hearing           
          relating to the approximate $148,350 balance of petitioners’                
          unpaid 1993 Federal income taxes.                                           
               On July 21, 2005, petitioners filed a Form 12153, Request              
          for a Collection Due Process Hearing, with regard to respondent’s           
          notice of intent to levy, in which petitioners requested that               
          respondent reinstate the OIC.                                               









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