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collection of petitioner’s 1999 and 2000 Federal income tax
liabilities.2
Background
The parties submitted this case fully stipulated under Rule
122. We incorporate the stipulated facts and accompanying
exhibits into our findings by this reference. Petitioner resided
in Mill Valley, California, when she filed the petition.
For the taxable year 1990 through the taxable year 2000,
petitioner failed to pay the amounts of tax shown as due on her
returns. On February 10, 2002, respondent sent to petitioner a
Final Notice - Notice of Intent to Levy and Notice of Your Right
to a Hearing for the taxable years 1990 through 2000. On or
about March 11, 2002,3 petitioner submitted Form 12153, Request
for a Collection Due Process Hearing, requesting a hearing under
section 6330 with respect to the taxable years 1990 through 2000.
In pertinent part, petitioner’s Form 12153 stated:
The taxpayer has prepared, and is prepared to submit,
an Offer-In-Compromise based on doubt as to liability,
doubt as to collectability, and effective tax
2The parties agree that petitioner’s income tax liabilities
for the taxable years 1990 through 1998 were discharged in
bankruptcy. Although the parties’ briefs indicate disagreement
as to whether the discharge order applied to petitioner’s 1999
income tax liability, petitioner has not raised the issue before
this Court.
3Although the parties stipulated that petitioner submitted
her Form 12153 on Mar. 11, 2002, both the second page of
petitioner’s Form 12153 and petitioner’s representative’s
signature on the first page are dated Mar. 12, 2002.
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