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Background
Petitioner failed to file tax returns for 1995 and 1996. On
March 12, 1999, respondent issued notices of deficiency to
petitioner determining deficiencies in and additions to her
Federal income taxes for 1995 and 1996. Respondent determined
that petitioner failed to report wage income during the years in
question based upon information provided to respondent by third-
party payors.
On July 5, 2000, respondent mailed to petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing.
On July 31, 2000, petitioner filed with respondent a Request for
a Collection Due Process Hearing that included a request that
respondent provide petitioner with a summary record of
assessment, and any documents showing that petitioner is liable
for a specific tax.
On September 18, 2000, Appeals Officer Gerald D. Sackett
wrote a letter to petitioner enclosing transcripts of her
accounts to demonstrate that tax assessments had been entered
against her for 1995 and 1996. Petitioner’s case was
subsequently transferred to Appeals Officer Nancy D. Johnson.
Appeals Officer Johnson concluded that it was unclear whether
petitioner received the notices of deficiency dated March 12,
1999, and, therefore, informed petitioner that she would be
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Last modified: May 25, 2011