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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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Last modified: November 10, 2007