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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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Last modified: May 25, 2011