Gloria M. Stark - Page 5

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          Action(s) Under Section 6320 and/or 6330 (notice of                         
          determination) regarding petitioner’s 1994 through 1997 tax                 
          liabilities.  In the notice of determination, respondent                    
          determined that all applicable legal and administrative                     
          procedures had been met and that collection actions could proceed           
          against petitioner.  The notice of determination states:  “The              
          underlying tax liability is correct.  You were divorced and the             
          alimony payments received from your former husband are properly             
          included into income.”                                                      
               On June 3, 2002, this Court received from petitioner, who              
          then resided in Independence, Missouri, a letter which the Court            
          treated as a timely imperfect petition for review of respondent’s           
          notice of determination.  On June 26, 2002, petitioner filed an             
          amended petition.  In her amended petition, petitioner states               
          that she “does not contest the tax owed or any additions to the             
          tax for penalty or interest.  The petitioner merely states that             
          the IRS is billing the wrong person for the taxes owed for the              
          years 1994, 1995, 1996 and 1997.”  She contends that the Midland            
          County, Michigan, circuit judge who signed the divorce judgment             
          had been “previously disqualified from making any further rulings           
          between the two parties.”  Thus, she contends, there was “No                
          legal divorce” and consequently “no alimony” to be included in              
          her taxable income.                                                         

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