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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 and
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Last modified: May 25, 2011