- 2 - for decision is whether respondent’s determination to proceed with collection action should be sustained. FINDINGS OF FACT The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. At the time the petition in this case was filed, petitioner resided in Lafayette, California. Petitioner failed to timely file her Federal income tax returns for 1994, 1995, 1996, and 1997. Respondent filed substitutes for returns for each of those years. During the years at issue, petitioner was employed by the County of Contra Costa, California (County). She earned gross income from her employment of $40,317 in 1994, $41,961 in 1995, $46,906 in 1996, and $58,042.16 in 1997. Collection Activity for Prior Tax Years Respondent, having previously warned petitioner of impending wage attachments, sent notices of levy to the County with respect to her Federal income taxes for 1990, 1992, and 1993. The notice of levy dated December 15, 1997, was in the amount of $4,605.49 and the notice of levy dated January 15, 1998, was in the amount of $4,639.01.1 County technicians responsible for tracking garnishments and wage assignments prepared contemporaneous 1Both notices of levy concerned petitioner’s tax liabilities for 1990, 1992, and 1993, but the second notice was for a slightly larger amount due, apparently, to additional interest.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007