- 3 - As to the 1991 taxes, overpayment credits from subsequent years were applied to the balance due in 1997, 1998, and 1999. On December 13, 2000, “intent to levy collection”, “due process notice”, and “levy notice” (collection notices) were issued to petitioner and Mr. Clark for each of the years at issue. These notices were labeled as “refused/unclaimed” on December 30, 2000. Copies of the notices were not presented at trial. Petitioner claims that she never knew of or saw these notices. After Mr. Clark died on October 25, 2001, petitioner became aware that she could request relief from joint liability in connection with the tax liabilities described. On May 21, 2003, petitioner filed Form 8857, Request for Innocent Spouse Relief, and an attached Form 12510, Questionnaire for Requesting Spouse, which were received by respondent on May 30, 2003. In a notice of determination for 1991 and a preliminary notice of determination for 1992 and 1993, respondent denied and proposed to deny, respectively, petitioner’s request for relief from joint liability for her Federal income taxes under section 6015(b), (c), and (f). On October 24, 2003, respondent mailed to petitioner a final notice denying petitioner’s request for innocent spouse relief under section 6015(b), (c), and (f) for 1991. The notice stated that the request was denied because it was received “more than two years after the date * * * [the Internal Revenue Service]Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011