James E. Anderson and Cheryl J. Latos - Page 5

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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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