Filomena Pahamotang - Page 4

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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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