Jan Lister - Page 7




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          petitioner’s response by May 9, 2002.  Petitioner responded in a            
          letter to Ms. Dodson dated April 30, 2002.  Although several                
          exhibits were attached to the letter, none of the exhibits                  
          supplied the information requested by Ms. Dodson.  Petitioner’s             
          April 30, 2002, letter demanded that respondent pay her “all                
          allowances, credits, standard deductions, benefits 1993 through             
          2001.”                                                                      
               On May 9, 2002, the Appeals Office issued a Notice of                  
          Determination Concerning Collection Action(s) under Section 6320            
          and/or 6330 in which it determined the following:                           
               1.  All legal and procedural requirements for the issuance             
          of the Notice of Intent to Levy had been met.                               
               2.  Prior to the Appeals officer’s consideration of the                
          issues raised by petitioner, the Appeals officer had had no                 
          previous involvement with respect to petitioner’s 1993 and 1994             
          income tax liabilities.                                                     
               3.  None of the issues raised by petitioner were                       
          meritorious.                                                                
               4.  Petitioner did not raise any spousal defenses.                     
               5.  Petitioner was not entitled to challenge the underlying            
          liabilities for 1993 and 1994 because she had received notices of           
          deficiency for those years.                                                 
               6.  The proposed levy action balanced the need for efficient           
          collection of taxes with the legitimate concern of the taxpayer             






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