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submitted copies of her two granddaughters’ Social Security cards
and hospital birth records.
On November 29, 2000, respondent issued to petitioner a
notice of deficiency by certified mail in which respondent
determined that petitioner is not entitled to head of household
filing status, dependency exemptions, or the earned income
credit. The IRS subsequently sent other correspondence
concerning petitioner’s case to the same address, 13750 S.E. 26th
Street, Morriston, Florida, 32668, which petitioner received.
Petitioner submitted canceled checks and utility statements
in an attempt to obtain reconsideration of the deficiency.
Respondent reviewed the documentation and notified petitioner of
respondent’s refusal to change the determinations set forth in
the notice of deficiency.
B. Respondent’s Collection Actions
Respondent withheld petitioner’s 2000 Federal income tax
refund and applied it toward the outstanding tax liability for
1998. Respondent also withheld petitioner’s 2001 and 2002
Federal income tax refunds and applied them toward her 1998
balance.
On September 1, 2003, respondent issued to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing. Petitioner timely filed a Form 12153, Request for a
Collection Due Process Hearing (hearing), in which she asserted
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Last modified: May 25, 2011