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Petitioner's liability for 1992 as shown on her return was
assessed on January 10, 1994, and additional tax and a late
filing addition to tax for 1992 were assessed on January 9, 1995.
Petitioner's tax liability for 1993 as shown on her return and
late filing addition to tax were assessed on June 6, 1994. Her
tax liability for 1995 and a failure-to-pay addition to tax were
assessed on May 6, 1996. Petitioner's tax liability for 2000, as
shown on her return, was assessed on May 28, 2001, and additional
tax was assessed on October 21, 2002. Accordingly, assessment
was well within the 3-year period of limitations for all years.
Respondent received petitioner's Form 12153, Request for a
Collection Due Process Hearing, on January 14, 2003, well within
the applicable 10-year period of limitations for collection. The
running of the 10-year period was suspended by the Form 12153 and
remains suspended. Collection of petitioner's Federal income tax
liabilities for the years at issue is not time barred.
The Court has considered the other arguments raised by
petitioner and concludes they are either irrelevant or without
merit. The Appeals officer's refusal to accept petitioner's
arguments was not arbitrary, capricious, or without sound basis
in fact or law.
The Court holds that respondent may proceed with collection
action as determined in the notice.
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