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otherwise indicated, all section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioner resided in Texas at the time the petition was
filed. Petitioner filed her 1997 Federal individual income tax
return on October 21, 1999. On December 13, 1999, the tax
liability reflected on that return was assessed in the amount of
$16,502. Petitioner’s tax liability was partially offset by
Federal income tax withholding, and late filing and failure to
pay additions to tax and interest were assessed. Subsequently,
overpayments from 1999 and 2000 were applied to petitioner’s 1997
tax liability.
Petitioner filed her 1998 Federal income tax return on
February 9, 2001. On March 5, 2001, the tax liability reflected
on that return was assessed in the amount of $21,244.
Petitioner’s tax liability was partially offset by Federal income
tax withholding, and late filing and failure to pay additions to
tax and interest were assessed. As of September 9, 2001, the
total amount owing on petitioner’s Federal income tax liabilities
for 1997 and 1998 was $14,183.24.
On September 9, 2001, respondent sent to petitioner, in care
of Frank L. Zerjav (Zerjav), her authorized representative, a
Final Notice - Notice of Intent to Levy and Notice of Your Right
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Last modified: May 25, 2011