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Ann Picchiottino (Ms. Picchiottino) on April 15, 2002, reporting
a tax liability of $12,629.3
Petitioner did not fully pay the liability reflected on any
of the four returns. Respondent assessed the liabilities for
1997, 1998, 1999, and 2001 on November 18, 2002, November 25,
2002, October 21, 2002, and June 10, 2002, respectively.
On March 8, 2003, respondent issued to petitioner two Final
Notices of Intent To Levy and Notice of Your Right To A Hearing.
One pertained to liabilities for 1997, 1998, and 1999, and listed
a total amount due, including statutory additions, of $18,188.83.
The other addressed 2001 and provided a total amount due, again
including statutory additions, of $5,410.37.
In response to the notices petitioner timely submitted two
Forms 12153, Request for a Collection Due Process Hearing, dated
March 10, 2003. The Forms 12153 were filed with the Internal
Revenue Service (IRS) on or before March 27, 2003. One was in
petitioner’s name only and addressed 1997, 1998, and 1999.4 The
other was in the names of petitioner and Ms. Picchiottino and
3 One of the documents in the record may indicate that the
amount reported on the 2001 return was $12,929. In any event, a
possible discrepancy or ambiguity on this point is immaterial
here in that it is clear the amount assessed was only $12,629.
4 The Form 12153, Request for a Collection Due Process
Hearing, also listed 2000, but the record reflects no collection
notice or other activity with regard to that year.
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Last modified: May 25, 2011