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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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Last modified: May 25, 2011