- 11 - filed tax returns Form 1040 and Form 1040X.” Additionally, the notice of determination indicated that: “The Service has already considered and issued a separate determination letter on the Innocent Spouse issue.” Attachment 3193, attached to the notice of determination, provided: Issues Relating to the Unpaid Liabilities: The unpaid liabilities shown on the Notice of Intent to Levy (L-1058/LT-11) dated 06/27/1999 are from voluntarily filed original tax returns, Form 1040, or amended returns, Form 1040X. • Review of your account for the years 1989, 1990, 1992, and 1993 shows that the outstanding balances owed were for accrued interest on your amended returns. • Review of your account for the 1996 year shows that the outstanding balance owed included some of your original tax liability, penalty, and accrued interest. * * * * * * * The Notice of Intent to Levy dated 6/27/1999 did not include and [sic] amounts from the pending audit adjustments for 1989, 1990, 1992, or 1993. The proposed audit adjustments were considered separately by the Appeals office. A separate Statutory Notice of Deficiency was issued by the Appeals Office on April 4, 2000, and gave you the right to petition to the Tax Court. Those issues are not part of this Collection Due Process Hearing. Your claim for Innocent Spouse relief has also been considered separately by the Appeals Office and a separate determination letter was issued. That issue is not part of this Collection Due Process hearing. Respondent’s Appeals officer issued a statement in support of the notice of determination for petitioners’ 1989, 1990, 1992,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011