Laura Ann Flood - Page 3

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               Respondent issued a Letter 3193-c, Notice of Determination             
          Concerning Collection Action(s) Under Sections 6320 And/Or 6330,            
          in which respondent determined that the two Notices of Federal              
          Tax Lien filed against petitioner would not be released or                  
          withdrawn.  This Court must decide: (1) Whether petitioner is               
          entitled to amend her 1995 tax return, and (2) whether respondent           
          improperly considered petitioner’s section 401(k) plan as a means           
          of satisfying her tax liabilities.                                          
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioner resided in Alameda, California, at the time           
          she filed her petition.                                                     
               During taxable year 1995, petitioner, a legal secretary, was           
          married to Joseph F. Beharrysingh (Mr. Beharrysingh).  With the             
          concurrence of petitioner and for family reasons, Mr.                       
          Beharrysingh filed an individual income tax return, with the                
          filing status of married filing separate, for taxable year 1995.            
          Sometime thereafter, petitioner and Mr. Beharrysingh divorced.              
               On February 3, 1997, petitioner filed an individual income             
          tax return for 1995, dated “4/15/96", with the filing status of             
          married filing separate, and reported a total tax of $14,476,               
          less Federal withholding of $6,687.68, for an amount owed of                
          $7,788.36.                                                                  
               Petitioner offered into evidence an unsigned and undated               
          Form 1040X, Amended U.S. Individual Income Tax Return, changing             






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