Silvia S. Rodriguez - Page 4

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          signatures.  On February 2, 1998, petitioner gave Fast a copy of            
          what appeared to be her 1996 return, dated August 11, 1997.  It             
          did not have an original signature.                                         
               On February 17, 1998, petitioner submitted a Form 656, Offer           
          in Compromise, to Fast.  In it, petitioner offered to pay $1,500            
          of the taxes she owed for 1988-89.  In a letter dated March 16,             
          1998, Fast told petitioner that she had received a copy of                  
          petitioner’s 1991 return that did not have an original signature.           
          Fast also told petitioner that respondent would not consider the            
          offer in compromise because respondent had no record that                   
          petitioner had filed original tax returns for 1991-95.  Fast also           
          told petitioner that respondent would begin to collect tax from             
          her on March 20, 1998, and that petitioner must file returns for            
          1991-95 before respondent would process her offer in compromise.            
               In April 1998, petitioner gave Fast what appeared to be                
          copies of her tax returns for 1992, dated August 5, 1993, and for           
          1993, dated August 1, 1994.  Those copies did not bear original             
          signatures.                                                                 
               Petitioner had not filed original returns for 1988-2000 as             
          of the time of trial, and had given Fast copies of what appeared            
          to be petitioner’s returns for only 4 of those 11 years.                    
          D.   Notice of Intent To Levy and Section 6330 Hearing                      
               On October 25, 1999, respondent issued to petitioner a                 
          Notice of Intent To Levy and Notice of Your Right to a Hearing              






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