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After petitioner failed to pay her 1994 income tax
liability, respondent, by means of certified mail dated April 11,
2000, sent petitioner a Form 1058, Final Notice--Notice of Intent
to Levy and Notice of Your Rights to a Hearing, as required under
section 6330. Petitioner timely mailed to respondent a Form
12153, Request for a Collection Due Process Hearing, and a Form
8857, Request for Innocent Spouse Relief. In addition to the
collection hearing, petitioner sought innocent spouse relief in
the amount of $45,617. Along with the requests for collection
hearing and spousal relief, petitioner submitted an attachment
claiming that she “thought that the statutory period of
limitations for tax assessment is three years from the time the
[1994] tax return was filed. I never received any tax bill or
assessment with the statutory time period.”
On January 31, 2002, an Appeals officer issued a Notice of
Determination Concerning Your Request for Relief from Joint and
Several Liability under section 6015 for petitioner’s 1994 tax
year. In that notice, petitioner was granted $33,378 of partial
relief leaving an unpaid income tax deficiency of $12,239 for
1994.
On January 29, 2002, another of respondent’s Appeals
officers sent petitioner a letter requesting financial
information in order for respondent to consider collection
alternatives, including an installment payment agreement.
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Last modified: May 25, 2011