Cheryl D. Flathers - Page 6




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               On July 24, 2000, respondent assessed petitioner’s tax, as             
          well as a penalty under section 6662(a) and interest as provided            
          by law, for her taxable year 1998.  (We shall refer to those                
          assessed amounts, as well as interest as provided by law accrued            
          after July 24, 2000, as petitioner’s unpaid liability for 1998.)            
               On July 24, 2000, respondent issued to petitioner a notice             
          of balance due with respect to petitioner’s unpaid liability for            
          1998.                                                                       
               On October 12, 2000, respondent issued to petitioner a final           
          notice of intent to levy and notice of your right to a hearing              
          (notice of intent to levy) with respect to the frivolous return             
          penalty under section 6702 regarding her 1998 return.                       
               On May 30, 2001, respondent issued to petitioner a notice of           
          Federal tax lien and your right to a hearing (notice of tax lien)           
          with respect to both petitioner’s unpaid liability for 1998 and             
          the frivolous return penalty under section 6702 regarding her               
          1998 return.                                                                
               On or about June 25, 2001, in response to the notice of                
          intent to levy and the notice of tax lien, petitioner filed Form            
          12153, Request for a Collection Due Process Hearing (Form 12153),           
          and requested a hearing with respondent’s Appeals Office (Appeals           
          Office).  Petitioner attached, inter alia, a seven-page document            
          to her Form 12153 (petitioner’s attachment to her Form 12153).              
          That document stated in pertinent part:                                     






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