Nance Eva Dehring - Page 2




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          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.             





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