Robert & Polly A. Gatlos - Page 3

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          this case was filed, petitioners resided in Nottingham,                     
          Pennsylvania.                                                               
               Petitioners timely filed joint Federal income tax returns              
          for 1996 and 1999 showing balances due.  Respondent assessed the            
          income tax liabilities shown on the returns as well as interest             
          and the additions to tax for failure to pay tax under section               
          6651(a)(2).                                                                 
               Petitioners made some payments that were applied to their              
          1996 and 1999 tax liabilities but did not pay the liabilities in            
          full.  Following the receipt of a communication from petitioners            
          in which petitioners claimed that they were not liable for any              
          income tax, respondent sent petitioners a Letter 1058, Final                
          Notice - Notice of Intent To Levy and Notice of Your Right to a             
          Hearing, dated July 2, 2002, with respect to their unpaid 1996              
          and 1999 tax liabilities.  The final notice was issued and signed           
          by Michael C. Sutton, a revenue officer, who was a GS-11 employee           
          of the Internal Revenue Service on the date the final notice was            
          issued.                                                                     
               On July 30, 2002, respondent received a “Claim for Relief              
          From Alleged Notice of Lien or Levy” from petitioners in which              
          petitioners asserted various frivolous arguments.  Because of the           
          frivolous nature of petitioners’ arguments, respondent initially            
          refused to treat the claim as a timely request for a hearing                
          under section 6330 and initiated a levy action against                      






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