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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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Last modified: November 10, 2007