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121.1 As discussed in detail below, we shall grant respondent’s
motion.
Background
On October 7, 1997, respondent received a Form 870-AD, Offer
to Waive Restrictions on Assessment and Collection of Tax
Deficiency and to Accept Overassessment, showing signatures of
Bonnie W. Deese (Mr. Deese) and his wife Gladys Deese (Ms.
Deese), consenting to the immediate assessment and collection of
specified deficiencies in their joint Federal tax liabilities for
taxable years 1990 through 1994. On December 26, 1997, Mr. Deese
died. On February 9, 1998, respondent assessed these agreed-upon
deficiencies along with interest.
On August 21, 2002, respondent sent the deceased Mr. Deese a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC Section 6320 with respect to taxable years 1991, 1993,
and 1994. No collection hearing was requested in response to
this notice.
On February 23, 2005, respondent sent the deceased Mr. Deese
another Notice of Federal Tax Lien Filing and Your Right to a
Hearing Under IRC Section 6320, this time for taxable years 1990
through 1994. In response to this notice, on April 4, 2005,
1 Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years at issue.
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