Natalie W. McGee - Page 1

                                   123 T.C. No. 19                                    

                               UNITED STATES TAX COURT                                

                          NATALIE W. MCGEE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2884-03.           Filed October 18, 2004.                  

                    By notice of determination dated Nov. 22, 2002, R                 
               denied P’s request for relief under the equitable relief               
               provisions of sec. 6015(f), I.R.C., for the taxable year               
               1997 solely because P’s request was made more than 2                   
               years after R’s first collection activity on the 1997                  
               account.  In May 1999, R withheld a $291 refund P claimed              
               on her 1998 individual Federal income tax return to                    
               partially offset the unpaid 1997 joint liability.  R’s                 
               related notice of offset did not advise P of her rights                
               to seek relief under sec. 6015, I.R.C.                                 
                    Held: The May 1999 offset was a collection action.                
               Campbell v. Commissioner, 121 T.C. 290 (2003).                         
                    Held, further, The Commissioner is required to                    
               include with collection-related notices, such as the                   
               letter sent to P informing her of the withholding of her               
               refund for 1998, a description of taxpayers’ rights under              

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