- 2 - petitioner is entitled to question the underlying merits of her 1993 and 1994 income tax liabilities. FINDINGS OF FACT1 June H. Ginalski, petitioner, resided in Phoenix, Arizona, at the time her petition was filed. Upon notification that respondent had filed a Notice of Federal Tax Lien with respect to petitioner’s 1993 and 1994 income tax liabilities, petitioner timely requested a hearing before an Appeals officer. At the hearing, petitioner sought to question the underlying merits of her 1993 and 1994 tax liabilities which, to some extent, involved whether amounts received by petitioner in connection with a divorce were income to her. Petitioner did not wish to discuss collection alternatives or other collection-related matters. The Appeals officer refused to discuss the merits of the underlying liabilities because petitioner had received a notice of deficiency for her 1993 and 1994 tax years and had filed a petition with this Court. After a trial on the merits of her 1993 and 1994 income tax, it was held in a Tax Court Summary Opinion that the amounts petitioner received during 1993 and 1994 from her divorce proceeding were taxable to petitioner for those years. Pursuant to this Court’s decision, respondent assessed 1 At trial, the parties stipulated facts and exhibits and presented oral argument.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011