James E. Anderson and Cheryl J. Latos - Page 17




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          notice of tax lien and gave the following explanation for her               
          disagreement:                                                               
               NOT SELF-EMPLOYED                                                      
               IRC Sec. 3403                                                          
                    3102(b)                                                           
               On January 24, 2006, a settlement officer held a telephonic            
          conference with Ms. Latos with respect to the 1995 through 1997             
          notice of tax lien.  During that conference, Ms. Latos claimed              
          that neither she nor Mr. Anderson is responsible for paying                 
          income tax on the respective amounts that Mr. Anderson received             
          during 1995,12 1996, and 1997 from his fishing activities.                  
          Instead, according to Ms. Latos, the alleged employer of Mr.                
          Anderson during those years is responsible for paying such tax.             
               On February 16, 2006, the Appeals Office issued to Ms. Latos           
          a notice of determination with respect to, inter alia, her                  
          taxable years 1995 through 1997 (1995 through 1997 notice of                
          determination).  That notice stated in pertinent part:                      
               Summary of Determination                                               
               The Federal Tax Lien is sustained.                                     
          An attachment to the 1995 through 1997 notice of determination              
          stated in pertinent part:                                                   




               12As discussed above, Ms. Latos’ unpaid 1995 liability is              
          based on respondent’s determination of a deficiency in self-                
          employment tax, and not income tax, for her taxable year 1995.              
          See discussion infra note 20 regarding the nature of the self-              
          employment tax.                                                             





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