- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008