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On June 21, 1999, respondent sent petitioner a notice of
deficiency for 1995, 1996, and 1997, determining income tax
deficiencies of $7,054, $6,305, and $6,711, respectively, plus
additions to tax under sections 6651(a)(1) and 6654 for 1995 and
1997. Petitioner did not petition this Court for
redetermination.
On March 29, 1999, respondent assessed the unpaid tax
liability reported on petitioner’s 1994 tax return, plus
penalties and interest. On February 7, 2000, respondent assessed
the income tax deficiencies and additions to tax, plus interest,
as determined in the notice of deficiency for 1995, 1996, and
1997.
On June 15, 2000, respondent sent petitioner a Final Notice
-- Notice of Intent to Levy and Notice of Your Right to a
Hearing, regarding petitioner’s 1994 through 1997 income tax
liabilities. On July 12, 2000, petitioner submitted to
respondent a Form 12153, Request for a Collection Due Process
Hearing. On the Form 12153, the only issue that petitioner
raised was whether payments received from her former husband were
taxable to her as alimony.
On April 10, 2001, an administrative hearing was held
between petitioner and respondent’s Appeals officer (the
administrative hearing). On April 30, 2002, respondent issued
petitioner a Notice of Determination Concerning Collection
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