- 3 - Soon after the case was transferred, the IRS requested that petitioner and her spouse consent to extending the period of limitations for assessment of the tax due on the 1990 tax return. When they refused to consent to the extension, the IRS disallowed their claimed Schedule C expenses due to lack of substantiation. The disallowance of the Schedule C expenses, which also led to the disallowance of a small amount of itemized deductions on Schedule A, resulted in a deficiency of $3,204. Respondent prepared a statutory notice of deficiency dated July 22, 1997, for issuance to petitioner and her spouse for 1990, reflecting a deficiency of $3,204 and additions to tax under section 6651(a)(1) and (2) and an accuracy-related penalty under section 6662. No petition for a redetermination of the deficiency was filed in this Court, and the IRS assessed the deficiency, additions, and penalty on December 19, 1997. In September of 1999 the IRS sent to petitioner and her spouse Letter 1058, Final Notice of Intent to Levy and Notice of Your Right to a Hearing. The letter notified them that the IRS intended to levy on their property and rights to property to collect their unpaid liabilities for 1990, and of their right to request a hearing with the Appeals Office before execution of the levy. Although petitioner received a copy of the notice of intent to levy and right to a hearing, she did not request a hearing with Appeals.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011