- 6 - 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-Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011