Homer W. and Nancy L. Winans - Page 4

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          Federal income tax return and gave petitioners the opportunity to           
          submit a corrected return.                                                  
               Respondent determined that petitioners had unreported wage             
          and self-employment income based on third-party information                 
          returns submitted to respondent for each of the years 1996-2001.            
          Respondent later mailed notices of deficiency to petitioners for            
          1996-2001.  Petitioners timely received the notices of                      
          deficiency.  They did not file a petition for redetermination               
          with the Tax Court because they asserted that the notices were              
          C.   Respondent’s Collection Notices and Petitioners’ Requests              
               for an Administrative Hearing                                          
               Respondent assessed the taxes and additions to tax                     
          determined in the notices of deficiency for 1996-2001.                      
               On September 23, 2000, respondent mailed to petitioner a               
          Final Notice of Intent to Levy and Notice Of Your Right to a                
          Hearing Under Section 6330 for 1996-1998.  Although petitioner              
          contends that he submitted to respondent a Form 12153, Request              
          for Collection Due Process Hearing, challenging the levy notice,            
          the record does not include a copy of the request.  In November             
          2003, respondent began to collect petitioners’ unpaid taxes for             
          1996-1998 by levying on petitioner’s wages.                                 
               In December 2003, petitioners filed with the Taxpayer                  
          Advocate Service (TAS) a Form 911, Application for Taxpayer                 
          Assistance Order, for 1996-2000.  Petitioners also submitted to             

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