Donald R. Cooley and Cathy A. Cooley - Page 14

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               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                       




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