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Hearing under section 6330, in which she asserted that her former
spouse was responsible for the unpaid taxes.
On February 18, 2004, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s)
(Determination Notice) that acknowledged petitioner asserted in
her collection hearing request that her former spouse was
responsible for the tax liabilities. Respondent explained,
however, that because petitioner had “been through the Innocent
Spouse claim process, you know that both you and your ex-spouse
are separately responsible for the entire amount of the joint
liability.” The Determination Notice also stated that petitioner
failed to raise an appropriate spousal defense. Respondent
determined in the Determination Notice that the filing of the
notice of Federal tax lien was appropriate.
On March 19, 2004, petitioner filed with the Court a
petition for lien or levy action challenging respondent’s
Determination Notice.2 Petitioner’s sole contention is that she
paid her fair share of the unpaid tax liabilities.
As previously mentioned, respondent filed a Motion for
Summary Judgment. Petitioner filed an objection to respondent’s
motion on May 5, 2005, repeating her assertion that her former
spouse is responsible for the tax liabilities.
2 The parties do not dispute that the petition in this case
was timely filed under secs. 6330 and 7502(a).
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