Shuang-Di Sun Bennett - Page 7

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               On June 17, 2001, petitioner submitted an amended 1998                 
          return, on which she reported no taxable income, no taxes                   
          withheld, and a tax liability of zero.  Petitioner did not submit           
          a corrected Form W-2 with the amended return.  Petitioner’s                 
          amended 1998 return was received on June 17, 2001, but respondent           
          did not process the amended return.                                         
               On March 12, 2002, respondent issued to petitioner a Final             
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing.  Petitioner timely filed a Form 12153, Request for a               
          Collection Due Process Hearing, on which petitioner stated, in              
          pertinent part:                                                             
               I came to U.S.A. 9-1-1994 and I have never worked at                   
               all.  My ex-husband put me on his partner’s company                    
               payroll for insurance but I have never received any pay                
               from any source. * * * He prepared the tax form for my                 
               signature and I signed it without looking at or                        
               understanding the form.  I had no income from any job                  
               in 1998.  My request for an amended W-2 Form was                       
               refused. * * *                                                         
               On September 10, 2002, an administrative hearing was held              
          between petitioner and a hearing officer from the IRS Office of             
          Appeals. On March 21, 2003, respondent issued to petitioner the             
          notice of determination.  In the notice, respondent determined              
          that it was appropriate to proceed with collection.  The notice             
          provided the following explanation, in pertinent part:                      
               The taxpayer appeared for the conference and reiterated                
               the argument presented in the Request for a Collection                 
               Due Process Hearing.  The taxpayer was given an                        
               opportunity to provide evidence to support her argument                
               that she did not earn wages [from] her former husband’s                

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