- 14 -
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.
You raised the issue that “the amount due had not been
determined”.
The unpaid tax liability shown on the Notice of Intent to
Levy (L-1058) dated 03/09/2000 was from your voluntarily
filed tax returns, Form 1040 or 1040X.
Review of your account for 1991 shows that the outstanding
balance owed was for accrued interest on your amended
return.
Your claim for Innocent Spouse relief has also been
considered separately by the Appeals Office and a
separate determination letter was issued. The Innocent
Spouse determination is not part of this Collection Due
Process hearing.
Respondent’s Appeals officer issued a statement in support
of the 1991 notice of determination. The 1991 Appeals officer’s
supporting statement said: “IDRS shows that these CDP account
balances are for outstanding balances owed on their voluntarily
filed original and amended returns. Generally, the taxpayer full
paid the tax but has not paid the interest.” Moreover, the
Appeals officer’s supporting statement responded to petitioners’
assertion that no notice of deficiency for 1991 had been issued:
2. Relevant Issues Presented by the Taxpayer
* * * * * * *
The CDP Appeals officer reviewed the IDRS transcripts.
The outstanding balance owed and shown on L-1058 that
was issued by COLLECTION on 03/09/2000 is from interest
assessed and accrued on the voluntarily filed original
and amended returns.
The CDP Appeals Officer informed the representative
that the proposed audit adjustments shown in the
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011