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On June 27, 2000, and July 17, 2000, Mr. Angeli faxed
correspondence to respondent alleging that the Hendrickses had
settled the 1983 tax liabilities and questioned the propriety and
timeliness of the 1983 assessment. Respondent sent a letter to
the Hendrickses dated October 26, 2000, explaining the origin of
the 1983 tax liability in the TEFRA proceeding and attaching
copies of the various notices sent to the Hendrickses over the
years from the time the proceeding began. Respondent included
transcripts of account showing that while the 1980-82 tax
liabilities had been assessed and paid, the 1983 deficiency had
not been assessed until February 16, 2000, because of the stay on
assessment caused by the TEFRA proceeding.
Respondent filed a Notice of Federal Tax Lien in Larimer
County, Colorado, for the assessed 1983 tax liability and sent
the Hendrickses a Notice of Federal Tax Lien and Your Right to a
Hearing Under IRC 6320 on November 20, 2000.
On December 20, 2000, petitioner and Mr. Hendricks submitted
their separate Forms 12153, Request for a Collection Due Process
Hearing, and petitioner submitted a Form 8857, Request for
Innocent Spouse Relief. A hearing was held by telephone on
February 11, 2003. Respondent issued separate notices of
determination to petitioner and Mr. Hendricks on June 6, 2003,
sustaining the filing of notices of Federal tax lien and denying
relief to petitioner under section 6015.
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