- 3 - returns were "bogus" because she would never file her tax returns "in my maiden name" as she is legally separated, not divorced. The petition further alleges that "a Mary Ellen Brown + her husband, who have swindled me over 23 years, bribed" an IRS employee. Petitioner also alleges that "1 year is the limit for filing against anyone in a superior, or appellate court. By the statues [sic] of limitation their arguement [sic] is bogus." Other allegations in the petition concern an alleged robbery, alleged payments to her by her husband, and an allegation that petitioner (whose returns describe her profession as nursing) has engaged in the practice of law "in my own behalf in California." In her amended petition, petitioner alleges that she does not owe any tax because she "did the long forms in 1992, 1993 and 1995" and sent in a cashier's check for $860.73, and she realleges that there is a 1-year statute of limitations that prohibits respondent's collection action. Discussion Section 6330(c) prescribes the matters that a person may raise at an Appeals Office hearing. Section 6330(c)(2)(A) provides that a person may raise collection issues such as spousal defenses, the appropriateness of the Commissioner's intended collection action, and possible alternative means of collection. See Sego v. Commissioner, 114 T.C. 604, 609 (2000);Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011