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and (3) levy proceeds of $1,935.23, and $489.11 were applied to
1993 on March 20, 1998.
Assessment Activity for 1994 Through 1997
On November 10, 1998, respondent notified petitioner that
there was no record that she had filed Federal income tax returns
for the years at issue. Respondent sent to petitioner on April
9, 1999, a notice of deficiency for 1994, 1995, and 1996 and a
notice of deficiency for 1997, all by certified mail. The
notices of deficiency were addressed to petitioner at P.O. Box
1692, Lafayette, California 94549, the same address that is on
the petition in this case.
On September 20, 1999, respondent sent to petitioner two
notices requesting payment for taxes for 1994 and 1995. On
October 8, 1999, petitioner wrote to respondent to request a
hearing to “appeal the examination notices of Sept. 20, 1999, for
the years 1994, 1995, 1996 and 1997.” Petitioner attached to the
letter a copy of a statement of account for each of the years at
issue.
Appeals Officer Patricia Fu in a letter dated November 24,
1999, informed petitioner that her case had been assigned to the
Appeals Office in San Francisco, California. Petitioner filed a
claim for refund of $42,839 of tax for the years at issue.
Appeals Officer Fu, after reviewing “IRP” documents, allowed a
partial adjustment of $7,858 for previously uncredited
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