- 4 - year 1997 based on the return. Prior to trial, the tax pertaining to the 1997 return was paid in full. The Court dismissed the 1997 tax year from the petition. Mrs. Nicol was dismissed from the case because she had no involvement in the 1993 tax year which pertained solely to petitioner's individual income tax liability. B. Notice of Intent To Levy and Notice of Federal Lien The Nicols previously had an installment agreement in place covering 1993 and 1997. They stopped making the $50 monthly payments under that agreement and respondent found them to be in default. Respondent sent petitioner a Notice of Intent to Levy dated July 24, 2000. On October 19, 2000, respondent sent petitioner a Final Notice, Notice of Intent to Levy, and Notice of Your Right to a Hearing for unpaid taxes in the amount of $9,443.31 for 1993. Subsequently, respondent filed a Notice of Federal Tax Lien on May 24, 2001. C. Appeals Office Hearing On June 8, 2001, Mrs. Nicol filed a Form 12153, Request for a Collection Due Process Hearing (CDP Hearing), and attached a Form 8379, Injured Spouse Claim and Allocation, for tax year 1997. On that same date, petitioner also filed a Form 12153 for tax year 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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