Rosie L. Moore - Page 6

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               Relevant Issues Presented by the Taxpayer                              
               Challenge to the amount of the liability                               
               You indicate in the Form 12153 that you do not agree                   
               with the amount of the liability.                                      
               A statutory notice of deficiency was issued on                         
               10/29/2002 to:                                                         
                    Rosie Moore                                                       
                    2839 Coach Dr Apt 3                                               
                    Memphis, TN 38128                                                 
               The notice was not returned by the Post Office as                      
               undeliverable or unclaimed.                                            
               A copy of the notice is in the file.                                   
               When asked during the hearing whether you received the                 
               statutory notice * * * you stated that you could not                   
               recall.                                                                
               The information in the file shows that you requested                   
               and received reconsideration of your audit.  However,                  
               the audit adjustments were unchanged.  The Appeals                     
               Officer explained that head of household filing status                 
               and the earned income credit were not allowed since it                 
               was determined that you did not meet the definition of                 
               “certain married individuals living apart” found in IRC                
               �7703.                                                                 
               Since you were previously given the opportunity to                     
               contest the liability, the liability issue cannot be                   
               considered in the Collection Due Process Hearing.                      
               Challenges to the appropriateness                                      
               of the collection action                                               
               You raised no specific challenge to the appropriateness                
               of the collection action.                                              
               Other issues                                                           
               In a letter dated 9/16/2004, the Appeals Officer ad-                   
               vised you that to be considered for an installment                     
               agreement or offer in compromise, you must provide a                   
               completed Collection Information Statement (Form 433-                  





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