- 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