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and (b)(1) for 1998. Petitioner received this notice of
deficiency.
Petitioner did not petition the Court for redetermination of
the deficiencies or penalties with respect to 1996, 1997, or
1998. On June 14, 1999, respondent assessed petitioner’s tax
liabilities, along with penalties and interest, for 1996 and
1997. On August 7, 2000, respondent assessed petitioner’s tax
liability, along with penalties and interest, for 1998.
On or about June 7, 2001, respondent filed a Notice of
Federal Tax Lien regarding petitioner’s income tax liabilities
for 1996, 1997, 1998, 1999, and 2000 with the county auditor of
King County, Seattle, Washington (tax lien). The tax lien listed
the following amounts owed:
Tax Period Type of Tax Amount Owed
1996 1040 $6,452.24
1997 1040 15,190.72
1998 1040 23,781.91
1996 CIVP 500.00
1997 CIVP 500.00
1998 CIVP 500.00
1999 CIVP 500.00
2000 CIVP 500.00
On June 12, 2001, respondent issued to petitioner a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 regarding her income tax liabilities for 1996, 1997, and
1998 (hearing notice).
On or about June 25, 2001, petitioner submitted a Form
12153, Request for a Collection Due Process Hearing, regarding
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Last modified: May 25, 2011