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The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination). Pursuant to section
6330(d), petitioner seeks review of respondent’s determination to
proceed with collection of her tax liability of $1,837.02 for
1998. The issue for decision is whether the Appeals officer
abused her discretion in sustaining a proposed levy to collect
petitioner’s unpaid income tax liability.
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioner
resided in Bristol, Virginia, at the time the petition was filed.
Background
A. Petitioner’s 1998 Tax Return
Petitioner timely filed her Form 1040, U.S. Individual
Income Tax Return, for 1998 as a head of household. On that
return, she claimed four dependency exemptions and an earned
income credit for two qualifying children. Respondent issued
petitioner a refund of $3,528.
Respondent later notified petitioner that her 1998 return
was being examined because another individual had claimed the
same children. Respondent requested documentation to verify
petitioner’s claimed exemptions and credit.
Petitioner submitted a copy of her daughter’s driver’s
license, Social Security card, and birth certificate. She also
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