- 2 - response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Background On April 12, 1999, respondent assessed $1,846.02 pertaining to petitioners’ Federal income tax liabilities for the 1996 year. Thereafter, on February 25, 2000, respondent issued to petitioners separate identical notices of deficiency for the taxable year 1997. The notices reflected a deficiency of $24,773 and an accuracy-related penalty under section 6662(a) of $4,234. The notices were sent by certified mail to petitioners at P.O. Box 425, Magee, Mississippi 39111-0425-257. In response to the notices of deficiency, petitioners apparently prepared a petition to the Tax Court for redetermination. They attached to their pleadings in the instant collection case a copy of a petition with respect to the deficiency signed and dated March 18, 2000. Such a petition, however, was never in fact filed with this Court, and no deficiency proceedings were instituted. Respondent assessed an unpaid balance of $34,760.65 with respect to 1997 on July 17, 2000. On or about December 5, 2000, respondent issued to petitioners a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing with regard to their 1996 and 1997 taxable years. Subsequently, on March 29, 2001, respondent sent to petitioners separate Notices of Federal Tax Lien Filing andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011