Deborah Carman Goodin - Page 4

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          Appeals Office hearing with petitioner with respect to the notice           
          of tax lien.  In connection with the telephonic Appeals Office              
          hearing, the settlement officer relied on transcripts of peti-              
          tioner’s accounts with respect to petitioner’s taxable years                
          1997, 1998, and 1999.                                                       
               On a date not disclosed by the record, respondent sent to              
          petitioner by facsimile (respondent’s facsimile) pertinent                  
          sections of the Code, the income tax regulations, and various               
          court cases which establish that petitioner is obligated to pay             
          tax, as well as any additions to tax and interest as provided by            
          law, for each of her taxable years 1997, 1998, and 1999.                    
               On March 10, 2004, in response to respondent’s facsimile,              
          petitioner sent to respondent by facsimile a letter (petitioner’s           
          March 10, 2004 letter) that stated in pertinent part:                       
               I specified on form 12153 that the notice of * * * lien                
               were Mathematically incorrect.  And my question to you                 
               was; Where is the statute and implementing regulation                  
               that makes me liable for the penalty or tax? * * * I                   
               have a copy of the IRC and the part of the Index, in                   
               the front under the subject of “Liability for tax”                     
               doesn’t even mention Subtitles A through C income                      
               taxes.  I have been looking at the laws and IRC Statues                
               and Regulations and they show I’m not liable, but                      
               absolutely none that show that I am.  I am not refusing                
               to pay I will gladly pay as you are requesting if you                  
               would please show me the law that says I have “gross                   
               income” form a taxable “situs” under 26 CFR � 1.861-                   
               8(f) that is legally considered as “taxable income”.                   
               Please just show me the amount of tax I owe in a way                   
               that is consistent with Section 861 of the IRC and the                 
               implementing regulation and statute. [Reproduced liter-                
               On April 16, 2004, the Appeals Office issued to petitioner a           

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