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On or about January 13, 1999, the problem resolution officer
recommended that petitioners’ 1995 tax liability should be
reduced by $2,525. The problem resolution officer’s
recommendation was based on his conclusion that Mr. Anderson was
an employee (not self-employed) for 1995. On February 8, 1999,
petitioners’ $9,222.43 assessment for 1995 was reduced to
$7,862.29.
On February 3, 1999, respondent issued a Final Notice--
Notice of Intent to Levy and Notice of Your Right To A Hearing
to petitioners for their outstanding tax liabilities for 1994
through 1997. Petitioners, in a document received by respondent
on March 1, 1999, submitted Form 12153, Request For A Collection
Due Process Hearing (petitioners’ request for an administrative
hearing), along with a letter protesting respondent’s attempt to
collect the 1994 through 1997 tax liabilities.
On April 30, 1999, respondent’s Appeals officer met with Ms.
Latos and discussed petitioners’ collection case. Ms. Latos
contended that petitioners were not liable for the 1996 and 1997
income tax. The Appeals officer explained to petitioners that
they had reported the 1996 and 1997 income tax liabilities and
had not sought to amend their returns. Ms. Latos also raised the
question of whether Mr. Anderson was self-employed or an employee
of the boat owners. Petitioners did not request any collection
alternatives or raise any other issue. Petitioners argued that
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Last modified: May 25, 2011