- 3 -
On April 10, 2001, respondent issued to each trust a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
relating to each trust’s 1996-97 tax years as follows:
Pepper Pot Trust 1996 $1,671.10
1997 27,511.54
Tuffy Ruffy Trust 1996 59,840.09
1997 90,344.89
Susan Bell Trust 1996 11,357.75
1997 44,049.10
Brandy Dandy Trust 1996 21,323.94
1997 56,283.41
On April 12, 2001, respondent filed with the Fresno County
Recorder’s Office a notice of Federal tax lien relating to each
trust’s income tax liabilities for tax years 1996-97. On April
17, 2001, respondent sent a notice to each trust that the notice
of Federal tax lien had been filed.
B. The Section 6330(b) Hearing
On May 3, 2001, the trusts each filed a Form 12153, Request
for a Collection Due Process Hearing, for tax years 1996-97 in
which they contended that: (1) Section 861 and the regulations
thereunder preclude the income at issue in these cases from being
taxable, and (2) the regulations upon which respondent relies are
invalid because they were not published in the Federal Register;
and asked that respondent give them case citations showing that
income is taxable.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011