Judy Hedrick Blosser - Page 2
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Appeals Office abused its discretion in sustaining respondent’s
proposed levy action against petitioner to collect income tax
liabilities for the taxable years 1994, 1995, and 1996 and
denying petitioner’s request for alternative collection methods.
We conclude that there are no genuine issues as to any material
facts, a decision may be rendered as a matter of law, and the
Appeals Office abused its discretion.
At the time she filed her petition, petitioner resided in
Petitioner did not file Federal income tax returns for
taxable year 1994, 1995, or 1996. Respondent issued notices of
deficiency for those years and determined tax deficiencies of
$2,892, $6,368, and $2,937, respectively.
On November 22, 2005, respondent mailed to petitioner a
Letter L-1058, Final Notice of Intent to Levy and Notice of Your
Right to a Hearing, informing petitioner that respondent proposed
to levy on her property to collect Federal income taxes owed for
1994, 1995, and 1996. After assessing penalties and interest and
applying withholding credits, respondent determined that
petitioner owed a total of $26,011.04.
On December 9, 2005, petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing, regarding the
proposed levy. Petitioner claimed that she could not afford to
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Last modified: November 10, 2007