Patricia Ann Blocker - Page 3

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          sent to petitioner a notice of deficiency determining a                     
          deficiency in tax of $3,412 for 1989 and additions to tax under             
          sections 6651(a) and 6654(a); that letter was sent to an address            
          on Roydon Drive in Houston, Texas.  The notice of deficiency was            
          returned to the IRS marked:  “MOVED, LEFT NO ADDRESS”.  The                 
          deficiency determination was based on third-party reporting of              
          wages earned by petitioner in 1989.  The notice of deficiency set           
          forth:  “Total income reported by payers (see income sources):              
          $23,374.00".  The amounts included in the notice were reported to           
          the IRS on Forms W-2, Wage and Tax Statement, that reflected an             
          address for petitioner on Jeanetta in Houston, Texas.                       
               When petitioner failed to respond to the November 24, 1993,            
          notice of deficiency, on April 18, 1994, the IRS assessed the               
          amounts determined in the notice and accrued interest.  When the            
          IRS received petitioner’s 1989 Form 1040, U.S. Individual Income            
          Tax Return, in 2000, the IRS assessed an additional amount of               
          $384, the difference between the amount determined in 1993 and              
          the amount of tax reported on petitioner’s return filed in 2000.            
               On June 16, 2003, the IRS sent to petitioner a Notice of               
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320.  The notice set forth petitioner’s unpaid liability for               
          1989 as $6,675.75, which included the two assessments of tax and            
          accrued additions to tax, penalties, and interest.  Petitioner              
          submitted a Request for a Collection Due Process Hearing.  On               






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