- 3 -
to petitioner’s failure to pay the income tax balances due, on
July 7, 1997, respondent assessed the income tax shown on the
returns and additions to tax for petitioner’s 1995 and 1996
taxable years:
Additions to tax--secs.
Year Income tax 6651(a)(1) 16651(a)(2) 6654
1995 $2,786 $486 $162 $114
1996 2,936 198 33 113
1On Sept 29, 1997, this penalty was abated by $54 for 1995
and by $33 for 1996.
Additionally, on July 7, 1997, respondent mailed petitioner
notices of balance due for 1995 and 1996.
On March 15, 1999, and again on July 24, 2000, respondent
mailed petitioner notices of intent to levy. On April 11, 2001,
respondent filed a Notice of Federal Tax Lien for the 1995 and
1996 income tax liabilities and, on April 16, 2001, sent
petitioner a Notice of Federal Tax Lien Filing as required by
section 6320. Petitioner mailed respondent a timely Form 12153,
Request for a Collection Due Process Hearing, on May 9, 2001. On
the Form 12153, petitioner claimed that she had experienced
“financial hardship” during the taxable years 1995 and 1996 and
that there was a “discrepancy” in her income tax liabilities for
those years. Petitioner also noted that she had filed a chapter
7 bankruptcy petition that covered the taxable year 1993.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011