- 4 - and/or 6330 on June 19, 2003 (notice of determination). Respondent stated, in part: For years 1996 and 1997, statutory notices of deficiency were mailed to taxpayer at the appropriate address. Accordingly, the underlying liability cannot be considered under CDP proceedings for these years. For tax years 1998, 2000, and 2001 the taxpayer did not present evidence to substantiate her position that the underlying liability was not appropriate as assessed. The filing of the Notice of Federal Tax Lien is appropriate. The liability is valid and outstanding. With respect to the proposed levy action for 2000 and 2001, respondent issued a separate notice of determination on June 19, 2003. Respondent sustained the proposed levy, stating in part: Taxpayer did not present evidence to substantiate her position that the underlying liability was not appropriate as assessed. The liability is valid and outstanding. Taxpayer did not propose any collection alternatives. Upon receiving the notices of determination, petitioner filed a petition with this Court. In addition, petitioner contacted respondent in an effort to arrange for a collection alternative. On June 26, 2003, petitioner sent respondent a package of documents purporting to be an offer in compromise (OIC). Petitioner did not provide specific information regarding her financial situation. She explained generally that she had limited resources and no relatives to help her, that she had lost her employment, that she lived very modestly, and that she anticipated incurring significant medical and long-term carePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011