Dorothy Ann Magee - Page 7

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               In response to respondent’s March 12, 2004, determination              
          letters, petitioner on March 31, 2004, timely filed a Petition              
          for Lien or Levy Action Under Code Section 6320(c) or 6330(d)               
          with this Court for the 1996 taxable year.  On May 21, 2004,                
          respondent filed an answer to petitioner’s petition and a                   
          certification under Rule 325(b).  See King v. Commissioner, 115             
          T.C. 118 (2000).  The certification confirmed that respondent               
          notified Mr. Magee that petitioner filed a claim for relief from            
          joint and several liability and that he could intervene.  Despite           
          the notice, Mr. Magee has not intervened in this case.                      
                                       OPINION                                        
          I.   Contentions of the Parties                                             
               Petitioner contends that she is not required to file a                 
          Federal income tax return for 1996.  Specifically, she asserts              
          that she did not generate a sufficient amount of income to                  
          require her to file a return.  In addition, with respect to the             
          1996 joint return, petitioner maintains that she is entitled to             
          relief from joint and several liability because her former spouse           
          forged her signature on the return.  Ultimately, petitioner                 
          claims that she never received a notice of deficiency for 1996,             
          that 1996 joint return was invalid, that liability on the 1996              
          joint return was incorrect, and that she was not given a proper             



               6(...continued)                                                        
          income tax return for 1996.                                                 



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