- 3 - “assignment”, deducted $92,923.47 from petitioner’s wages. In an attempt to determine where the $92,923.47 had been sent, the Appeals officer wrote to United and to the California Franchise Tax Board. On the basis of respondent’s records and those provided by the State of California, the Appeals officer determined that levy payments totaling $53,476.27 and $5,965.54 had been applied to petitioner’s 1992 and 1994 income tax accounts, respectively, and that in 1998 the State of California had received $12,109.23 in levy payments relating to petitioner’s State income tax liabilities. United and petitioner did not provide any documentation of payments received by respondent other than the payments reflected on respondent’s records. On February 7, 2002, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 relating to 1994. In response, on March 18, 2002, petitioner, while residing in San Diego, California, filed his petition with the Court. OPINION Petitioner contends that respondent erred in determining his 1994 tax liability because respondent used “married filing separately” filing status rather than “married filing jointly” status. Petitioner, however, received a statutory notice of deficiency relating to 1994 and, thus, is precluded from raisingPage: Previous 1 2 3 4 Next
Last modified: May 25, 2011