Similarly, on January 27, 2011 (i.e., roughly one year later), petitioners

hand-delivered to the Internal Revenue Service (IRS)--at the IRS office in

Houston, Texas--an $18,000 check from their account at JP Morgan Chase, NA.

They requested that the check be applied against their 2009 income tax liability

(slightly more than $18,000). Respondent initially applied the check against

petitioners’ 2009 income tax liability.

      On January 31, 2011, respondent issued a notice of intent to levy with

respect to petitioners’ 2001, 2002, 2004, 2006, 2008, and 2009 income tax




      7
       Of the payments petitioners made on their installment agreements, all were
applied against their 1999 income tax liability except for the December 18, 2006,
September 30, 2009, and January 5, 2010, payments.February 9, 2011, petitioners submitted to respondent a Form 12153,

Request for a Collection Due Process or Equivalent Hearing, with respect to their

unpaid income tax liabilities for 1995, 1996, 1999, 2000, 2001, 2002, 2003, 2004,

2006, 2008, and 2009. Petitioners checked the boxes for “Installment

Agreement”, “Offer in Compromise”, and “Other”. In the space provided next to

the “Other” box, petitioners referred respondent to an attachment. In their

attachment, petitioners contended that the period of limitations on collection had

expired with respect to their tax liabilities for 1995 and 1996. Petitioners also

noted that their January 27, 2011, check had not been deposited as of January 31,


      8
          This notice was issued from an IRS office in Philadelphia, Pennsylvania.
  