- 5 - petitioner's payroll office informed her of a notice of tax levy it received from respondent. This was the first petitioner learned of the outstanding unpaid tax liability for 1994. Petitioner filed her 1995 tax return and reported an overpayment of $336.82, which the Internal Revenue Service (IRS) applied to the unpaid balance for the 1994 tax year. The IRS also applied an overpayment of $2,661.12 from Mr. Pierce's 1995 tax return to the unpaid balance from 1994. When petitioner's payroll office advised her of the levy notice, she also became aware that Mr. Pierce never filed their joint returns for 1992 and 1993. On April 29, 1996, petitioner filed her Federal income tax returns for 1992 and 1993 as married filing separate, claiming overpayments of $430.03 and $316.53 respectively. Petitioner filed her 1998 tax return claiming an overpayment of $464.22, which the IRS applied to the unpaid balance for 1994. On March 31, 2000 a "Final Notice – Notice of Intent to Levy and Notice of Your Right to a Hearing" letter was sent to both petitioner and Mr. Pierce. On April 7, 2000, petitioner timely submitted a request for a hearing. Petitioner submitted, with the request for the hearing, a Form 8857, Request for Innocent Spouse Relief, and an attached explanatory letter. On October 31, 2000, the Examination Division sent petitioner a letter requesting more information and documentationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011