Patricia A. Hendricks and John J. Hendricks - Page 9

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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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