Layvonne Newell - Page 3

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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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