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On October 18, 2000, petitioners filed amended returns in
response to respondent’s assessment of petitioners’ tax
liabilities for 1991-95. Petitioners reported lower tax
liabilities for 1991-95 in those amended returns than they had
reported in their original returns for those years.
Respondent assigned petitioners’ collection due process case
to Appeals Officer Vivian Watson (Watson) on April 26, 2001.
Watson attended job-related training from April 30 to May 11,
2001.
On May 22, 2001, Watson wrote to petitioners to schedule a
collection due process hearing for June 7, 2001. Watson enclosed
a Form 433-A, Collection Information Statement for Individuals,
that she asked petitioners to complete and return to her by June
6, 2001. Petitioners completed the Form 433-A and returned it to
Watson on June 6, 2001.
At petitioners’ request, Watson conducted the collection due
process hearing on June 6, 2001. Immediately after the hearing,
Watson wrote a letter to petitioners in which she enclosed a Form
433-B, Collection Information Statement for Businesses, to be
returned by June 20, 2001. Watson also asked for a copy of
petitioners’ original 1991-95 returns, spreadsheets used to
prepare the amended 1991-95 returns, and telecommunication bills
for expenses claimed on the amended 1991-95 returns. Petitioner
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