- 2 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011