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