- 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 thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011