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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,
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Last modified: May 25, 2011