- 3 -
for years 1995 through 1999. The total amount due for the 5
years was shown as $14,133.01. On November 15, 2000, respondent
received from petitioner a timely Form 12153, Request for a
Collection Due Process Hearing.
A hearing was conducted by telephone on May 3, 2002.
Following the hearing, on May 8, 2002, respondent issued to
petitioner the Notice of Determination Concerning Collection
Action(s) Under Section 6330 sustaining the proposed levy. The
notice summarized the determination as follows:
We have determined that the proposed levy is
appropriate. We considered the liability issues you
raised for tax years 1997, 1998 and 1999 and determined
that the liability should not be decreased. We did not
consider the liability issues you raised for tax years
1995 and 1996 because you received the statutory notice
of deficiency for those years.
An attachment to the notice then expanded on the foregoing
summary, under the heading “Relevant Issues Presented by the
Taxpayer”:
You have raised a liability issue regarding a
dependency exemption, head of household filing status,
and the earned income credit. These liability issues
for years 1995 and 1996 could not be discussed at the
hearing because you received the statutory notice of
deficiency. You failed to invoke the jurisdiction of
the U.S. Tax Court and the tax for 1995 and 1996 was
properly assessed. * * *
We did consider the liability issues you raised for tax
years 1997-1999 as part of the Collection Due Process
Hearing. However, you failed to provide any
documentation to show that you were entitled to claim a
dependent, head of household filing status and the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011