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later date”. Petitioner did not believe that this course of
action would result in any problems.
The Internal Revenue Service (IRS) did not issue petitioners
a statutory notice of deficiency for 1997 or 1998.
IRS Collection Efforts
The IRS concluded that petitioners’ individual tax return
for 1997 contained multiple mathematical errors. On June 10,
2000, after correcting the mathematical errors, the IRS assessed
a tax liability of $111,636.
The IRS concluded that petitioners’ individual tax return
for 1998 contained multiple mathematical errors. On July 17,
2000, after correcting the mathematical errors, the IRS assessed
a tax liability of $34,890.
Before collection proceedings, petitioner and Revenue
Officer Steve Lerner corresponded regarding petitioners’ unpaid
taxes and refund claims for 1997 and 1998.
On November 16, 2000, Revenue Officer Lerner issued a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing. On December 6, 2000, Revenue Officer Lerner advised
petitioners that he would delay filing the notice of Federal tax
lien until December 28, 2000, so that petitioners could file
amended income tax returns for 1997 and 1998. On December 27,
2000, Revenue Officer Lerner issued a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under IRC 6320.
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Last modified: May 25, 2011