Carol L. Van Dyke - Page 4

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          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);            






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