Carol L. Van Dyke - Page 7

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               Petitioner's liability for 1992 as shown on her return was             
          assessed on January 10, 1994, and additional tax and a late                 
          filing addition to tax for 1992 were assessed on January 9, 1995.           
          Petitioner's tax liability for 1993 as shown on her return and              
          late filing addition to tax were assessed on June 6, 1994.  Her             
          tax liability for 1995 and a failure-to-pay addition to tax were            
          assessed on May 6, 1996.  Petitioner's tax liability for 2000, as           
          shown on her return, was assessed on May 28, 2001, and additional           
          tax was assessed on October 21, 2002.  Accordingly, assessment              
          was well within the 3-year period of limitations for all years.             
          Respondent received petitioner's Form 12153, Request for a                  
          Collection Due Process Hearing, on January 14, 2003, well within            
          the applicable 10-year period of limitations for collection.  The           
          running of the 10-year period was suspended by the Form 12153 and           
          remains suspended.  Collection of petitioner's Federal income tax           
          liabilities for the years at issue is not time barred.                      
               The Court has considered the other arguments raised by                 
          petitioner and concludes they are either irrelevant or without              
          merit.  The Appeals officer's refusal to accept petitioner's                
          arguments was not arbitrary, capricious, or without sound basis             
          in fact or law.                                                             
               The Court holds that respondent may proceed with collection            
          action as determined in the notice.                                         








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