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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 documentation
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