Jeffrey Chou and Cindy Chou - Page 7




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          the levy notice was issued.  No Notice of Determination                     
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          for 2000 has ever been issued.                                              
               In an OIC submitted with respect to the requested section              
          6330 hearing and signed by each petitioner on July 27, 2004, it             
          was represented:  “In March, 2001, Jeff and Cindy had their tax             
          returns prepared and were told that they owed $1,962,365 in                 
          tentative AMT because of the exercise of his stock options.”                
               On January 31, 2005, Mrs. Chou filed a Form 8857, Request              
          for Innocent Spouse Relief, for 2000 and 2001.  The letter                  
          submitting Mrs. Chou’s claims stated that the claim was being               
          submitted as part of petitioners’ section 6330 hearing for 2001.            
          The request asserted:  “If Jeff and Cindy’s OIC is not granted,             
          then Cindy’s claim for innocent spouse relief should be granted             
          as to her since she did not cause the AMT liability and received            
          no economic benefit from Jeff’s exercise of his Cisco ISOs.”  No            
          representation was made in the Form 8857 concerning Mrs. Chou’s             
          knowledge of the tax due for 2000 at the time the return was                
          filed.                                                                      
               Appeals Officer Lawrence Dorr (Dorr) was assigned                      
          petitioners’ OIC, the proposed levy and lien actions with respect           
          to collection of petitioners’ reported liability for 2001, and              
          Mrs. Chou’s section 6015(f) relief claim.  On July 27, 2005,                
          responding to an inquiry from Dorr about her thoughts regarding             







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