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redetermination and thus, the notice of deficiency
was defaulted and the proposed deficiencies were
assessed. The liability as reflected in the
notice of deficiency was based upon the community
property laws of the State of Idaho and your
proportionate share of the community income.
• The assessments are deemed correct because you
have failed to present any credible evidence to
overcome the Commissioner’s presumption of
correctness. You have continued to procrastinate
with regards to providing additional information
or evidence to support your position. You have
made numerous arguments based upon moral,
religious, political, constitutional,
conscientious, or similar grounds which Appeals
believes are without merit.
• Appeals believes the proposed enforcement action
balances the need for the efficient collection of
taxes with your concerns as to the intrusiveness
of the action to be taken.
The notice of determination sent to Davina Sego set forth the
following:
Summary of Determination
The Service should proceed with the proposed levy action.
Matters Considered at your Appeals hearing
• The requirements of various applicable law or
administrative procedures have been met based upon
the best information available.
• No return was filed and thus, the spousal defense
is not applicable.
• No challenges were raised to the appropriateness
of the collection actions.
• No offers of collection alternatives were made.
• You believe the liability is invalid because you
either (1) had no sources of income, or (2) had no
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Last modified: May 25, 2011