- 17 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007