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credits from 2000 and 2002 in the amounts of $500 and $400 on
September 30, 2001, and August 4, 2003, respectively, to
partially offset petitioner’s and Mr. Magee’s unpaid 1996 joint
liability. Petitioner was notified of these transfers at her
last known address.
A notice of intent to levy was mailed to petitioner’s last
known address on September 30, 2003. A Final Notice of Intent to
Levy and Notice of Your Right to a Hearing was sent to petitioner
on October 7, 2003, with an account summary showing an amount due
of $3,570.80, which amount, at that time, included the assessed
balance, accrued interest, and an addition to tax. Petitioner
submitted her Form 12153, Request for a Collection Due Process
Hearing, on or about October 21, 2003, and submitted Form 8857,
Request for Innocent Spouse Relief, on or about October 23, 2003.
On February 6, 2004, the requested collection hearing with
an Appeals officer was held by telephone. At the hearing,
petitioner did not discuss any collection alternatives with the
Appeals officer. On March 12, 2004, the Appeals officer issued a
Notice of Determination Concerning Collection Action under
Section 6330 informing petitioner that the decision to upon levy
petitioner’s property was an appropriate action. Also on March
12, 2004, the Appeals officer issued a Notice of Determination
Concerning Your Request for Relief under the Equitable Relief
Provision of Section 6015(f) stating that no relief under section
6015(f) would be granted because petitioner requested relief more
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