- 16 -
engaged in fishing activities during 1996 and (2) that he was
self-employed when he engaged in such activities during 1997.
Consistent with the TAM, on February 8, 2002, respondent
assessed FICA tax with respect to Ms. Latos’ taxable year 1996.9
On the same date, respondent also assessed interest as provided
by law with respect to that year.
On November 12, 2003, respondent filed a notice of Federal
tax lien with respect to, inter alia, Ms. Latos’ taxable years
1995 through 1997 (1995 through 1997 tax lien filing).10
On November 12, 2003, respondent issued to Ms. Latos a
notice of Federal tax lien with respect to, inter alia, her
taxable years 1995 through 1997 (1995 through 1997 notice of tax
lien).11
On November 17, 2003, in response to the 1995 through 1997
notice of tax lien, Ms. Latos mailed to respondent Form 12153 and
requested a hearing with the Appeals Office. In that form, Ms.
Latos indicated that she did not agree with the 1995 through 1997
9See infra note 13.
10The amount with respect to Ms. Latos’ taxable year 1996
shown in the 1995 through 1997 tax lien filing under the heading
“Unpaid Balance” included, inter alia, the FICA tax and any
interest thereon that respondent assessed on Feb. 8, 2002. See
infra note 13.
11The amount with respect to Ms. Latos’ taxable year 1996
shown in the 1995 through 1997 notice of tax lien under the
heading “Amount Owed” included, inter alia, the FICA tax and any
interest thereon that respondent assessed on Feb. 8, 2002. See
infra note 13.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: November 10, 2007