Johnnie Ann Holliday - Page 2




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          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code as amended.                                           
                                     Background                                       
               Petitioner resided in Phoenix, Arizona, at the time that she           
          filed her petition in this case.  In response to a notice of                
          filing Federal tax lien for 1991, 1992, and 1993, petitioner sent           
          to the Internal Revenue Service (IRS) Office of Appeals a request           
          for a hearing dated September 27, 2000.  The request contained              
          language challenging petitioner’s tax liability and IRS                     
          procedures but did not address alternative methods of collection.           
               A hearing was held March 1, 2001, in response to                       
          petitioner’s request.  The Appeals officer commenced the hearing            
          by stating that the purpose of the hearing was “to explore                  
          collection alternatives to the outstanding tax liability for the            
          tax periods 1991, 1992, and 1993.”  Petitioner’s husband spoke              
          for petitioner at the hearing.  The Appeals officer stated that             
          he had requested the Form 4340, Certificate of Assessments,                 
          Payments and Other Specified Matters, and would mail it to                  
          petitioner when it became available.  Petitioner’s husband                  
          asserted that the form had to be provided at the hearing.                   
          Petitioner’s husband argued that “the IRS agency generally files            
          bogus tax returns for people”, petitioner was not required to               
          file a tax return, and petitioner had not received a valid notice           
          of deficiency.                                                              






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