Olen W. and Gwendolyn Wilborn - Page 3

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          response to a Notice of Determination Concerning Collection                 
          Action(s) Under Section 6320 and/or 6330.                                   
                                     Background                                       
               On April 12, 1999, respondent assessed $1,846.02 pertaining            
          to petitioners’ Federal income tax liabilities for the 1996 year.           
          Thereafter, on February 25, 2000, respondent issued to                      
          petitioners separate identical notices of deficiency for the                
          taxable year 1997.  The notices reflected a deficiency of $24,773           
          and an accuracy-related penalty under section 6662(a) of $4,234.            
          The notices were sent by certified mail to petitioners at P.O.              
          Box 425, Magee, Mississippi 39111-0425-257.  In response to the             
          notices of deficiency, petitioners apparently prepared a petition           
          to the Tax Court for redetermination.  They attached to their               
          pleadings in the instant collection case a copy of a petition               
          with respect to the deficiency signed and dated March 18, 2000.             
          Such a petition, however, was never in fact filed with this                 
          Court, and no deficiency proceedings were instituted.  Respondent           
          assessed an unpaid balance of $34,760.65 with respect to 1997 on            
          July 17, 2000.                                                              
               On or about December 5, 2000, respondent issued to                     
          petitioners a Final Notice - Notice of Intent to Levy and Notice            
          of Your Right to a Hearing with regard to their 1996 and 1997               
          taxable years.  Subsequently, on March 29, 2001, respondent sent            
          to petitioners separate Notices of Federal Tax Lien Filing and              






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