123 T.C. No. 19
UNITED STATES TAX COURT
NATALIE W. MCGEE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2884-03. Filed October 18, 2004.
By notice of determination dated Nov. 22, 2002, R
denied P’s request for relief under the equitable relief
provisions of sec. 6015(f), I.R.C., for the taxable year
1997 solely because P’s request was made more than 2
years after R’s first collection activity on the 1997
account. In May 1999, R withheld a $291 refund P claimed
on her 1998 individual Federal income tax return to
partially offset the unpaid 1997 joint liability. R’s
related notice of offset did not advise P of her rights
to seek relief under sec. 6015, I.R.C.
Held: The May 1999 offset was a collection action.
Campbell v. Commissioner, 121 T.C. 290 (2003).
Held, further, The Commissioner is required to
include with collection-related notices, such as the
letter sent to P informing her of the withholding of her
refund for 1998, a description of taxpayers’ rights under
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