Craig H. Bond and Jennifer Bond - Page 3




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          an enrolled return preparer, no information was provided to Mr.             
          Rehm at the conference.  Mr. Rehm communicated to Officer Heidle            
          the desire of petitioners to reopen the audit of their 2001                 
          return.                                                                     
               On December 29, 2005, Officer Heidle held a face-to-face               
          conference with petitioner Jennifer Bond (Mrs. Bond) and Mr.                
          Rehm.  Mrs. Bond raised questions regarding petitioners’ tax                
          liability for 2001 and reiterated petitioners’ request to reopen            
          the audit of their 2001 return.  Officer Heidle informed Mrs.               
          Bond that petitioners were precluded from contesting their                  
          underlying tax liability for 2001 because petitioners had already           
          been given an opportunity to do so when they received the October           
          27, 2004, notice of deficiency, which Mrs. Bond acknowledged                
          receiving.                                                                  
               On April 12, 2006, Officer Heidle sent petitioners a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330.  Officer Heidle determined that petitioners               
          were precluded from contesting their underlying tax liability and           
          concluded that respondent could proceed with the proposed                   
          collection action.                                                          
               On May 16, 2006, the petition was filed.  In their petition,           
          petitioners raised arguments relating only to their underlying              
          tax liability for 2001.                                                     








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