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On October 26, 1995, petitioner signed Form 5564, Notice of
Deficiency Waiver, consenting to the immediate assessment of the
deficiencies and penalties.2 No petition was ever filed by
petitioner in this Court or in any other court challenging her
1993 and 1994 tax liabilities.
Respondent assessed petitioner for the amounts determined in
the notice of deficiency on December 4, 1995. Thereafter, in
1997, petitioner filed amended returns claiming refunds for 1993
and 1994. The refund claims were based on the exemptions and
filing status that petitioner had claimed on her original returns
that were disallowed in the notice of deficiency and assessed.
She based her position on the advice of her cousin, Chester J.
Victor, Sr., who claimed to have expertise in this area.3
Respondent denied the refund requests on October 12, 1998.
On December 17, 2001, respondent issued to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing in connection with the assessed balance of income taxes
2 Also on Oct. 26, 1995, petitioner offered to pay the
deficiencies through an installment agreement by signing a Form
9465, Installment Agreement Request. However, because she was
not current in filing her 1999 through 2001 Federal income tax
returns at the time of her collection due process hearing,
petitioner was not eligible for an installment agreement.
3 Mr. Victor later assisted petitioner by signing as her
authorized representative Form 12153, Request for a Collection
Due Process Hearing, signing her petitions, and testifying at
trial.
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Last modified: May 25, 2011