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1997), September 24, 2001 (Ms. Davis, for 1998), and August 19,
2003 (Mr. Davis, for 1997 and 1998).
1999 Tax Liabilities
On April 7, 2003, respondent issued to petitioner JLD Asset
Management Trust, Jeffrey W. Davis, trustee (the trust and the
trustee, respectively), a notice of deficiency with respect to
the trust’s 1999 Federal income tax and issued to Mr. and Ms.
Davis a notice of deficiency with respect to their 1999 Federal
income tax. Neither the trustee, Mr. Davis, nor Ms. Davis filed
a petition for redetermination of the deficiency, and respondent
timely assessed the 1999 deficiencies and other amounts on August
19, 2003 (Mr. and Ms. Davis), and September 15, 2003 (the trust).
Notices
On March 15, 2004, respondent sent to each petitioner with
respect to each year of that petitioner in issue a Final Notice –
Notice of Intent to Levy and Notice of Your Right to a Hearing
(final notice).
On March 19, 2004, respondent sent to each petitioner with
respect to each year of that petitioner in issue a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (NFTL). Each NFTL notified the recipient that respondent
had filed a lien with respect to the recipient’s unpaid Federal
income tax liability (or liabilities) for the year (or years) in
issue.
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Last modified: November 10, 2007