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taxable year 1998 (1998 notice of tax lien).5
On December 17, 2001, in response to the 1998 notice of tax
lien, Ms. Latos mailed to respondent Form 12153 (Ms. Latos’ Form
12153 with respect to the 1998 notice of tax lien) and requested
a hearing with the Appeals Office. In that form, Ms. Latos
indicated that she did not agree with the 1998 notice of tax lien
and gave the following explanation for her disagreement: “Re-
quested Appeals Hearings for all 3 years - never received hear-
ings.” Attached to Ms. Latos’ Form 12153 with respect to the
1998 notice of tax lien was the first page of the two-page
attachment to Ms. Latos’ Form 12153 with respect to the 1998
notice of intent to levy.
On January 29, 2002, a settlement officer with the Appeals
Office (settlement officer) held a conference with Ms. Latos with
respect to the 1998 notice of intent to levy and the 1998 notice
of tax lien. During that conference, Ms. Latos claimed that
neither she nor Mr. Anderson is responsible for paying income tax
on the amounts that Mr. Anderson received during 1998 from his
fishing activities. Instead, according to Ms. Latos, the alleged
employer of Mr. Anderson during that year is responsible for
paying such income tax.
5Ms. Latos and respondent stipulated that respondent issued
the 1998 notice of tax lien to Ms. Latos on Dec. 6, 2001. That
stipulation is clearly contrary to the facts that we have found
are established by the record, and we shall disregard it. See
Cal-Maine Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989).
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Last modified: November 10, 2007