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Petitioner did not complete the forms or send any mortgage
statements to Neighbor. On March 9, 2000, petitioner asked
Neighbor to reschedule the hearing because she was ill. On March
22, 2000, Neighbor rescheduled the hearing for May 25, 2000, and
again asked petitioner to give him the information described
above.
On May 18, 2000, petitioner sent copies of her 1991, 1992,
1993, and 1996 returns to Neighbor. The copies did not bear
original signatures. On May 24, 2000, petitioner asked
respondent to postpone the May 25 hearing for health reasons.
She told Neighbor she would contact him after June 1, 2000.
By letter dated June 19, 2000, Neighbor told petitioner
that, in consideration of her health problems, he had postponed
the May 25 hearing, and she had until July 20, 2000, to propose
collection alternatives. Neighbor told petitioner that
respondent had received from petitioner copies of certain
returns, but that original returns had not been filed with the
IRS. He invited her to contact him so that they could schedule a
hearing before July 20, 2000. He told her that he would issue a
notice of determination after that time.
On July 10, 2000, petitioner told Neighbor that she had
filed original returns with the Philadelphia Service Center;
however, she did not say which returns she had filed. She also
asked Neighbor to postpone the July 20, 2000, deadline to August
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Last modified: May 25, 2011