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Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. The issue for decision is whether respondent may
proceed with collection action as so determined.
Background
On or about August 20, 2002, petitioner filed a Federal
income tax return for the year 2001. She reported thereon wage
income of $45,794, a tax liability of $4,256, a withholding
credit of $2,846, and a remaining amount due of $1,451. No
payment was submitted with the return. At that time, petitioner
also had outstanding tax liabilities for the 1995, 1996, and 1997
taxable years, all stemming likewise from self-reported amounts
in conjunction with insufficient withholding or other payment.
In August of 2002, petitioner entered into an installment
agreement with respondent to make appropriate payments to satisfy
her outstanding 1995, 1996, 1997, and 2001 liabilities. However,
shortly thereafter petitioner was diagnosed with brain cancer and
apparently defaulted on the installment agreement after a single
payment. She has since undergone brain surgery, chemotherapy,
and radiation treatments and has been unable to work. Petitioner
was previously employed as a registered nurse.
On or about September 23, 2002, respondent assessed the
reported 2001 liability, as well as statutory additions to tax
and interest. Subsequently, during April of 2003, Internal
Revenue Service (IRS) representatives of the Kansas City,
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