Estate of Bonnie W. Deese, Deceased, Gladys Deese, Personal Representative - Page 3




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          Ms. Deese, as personal representative of the deceased Mr. Deese,            
          submitted a Form 12153, Request for a Collection Due Process                
          Hearing (CDP hearing).                                                      
               After a face-to-face hearing between respondent’s Appeals              
          officer, Ms. Deese, and her C.P.A. representative, respondent’s             
          Appeals Office issued petitioner a Notice of Determination                  
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          for taxable years 1990 and 1992.  Respondent also issued                    
          petitioner a Decision Letter Concerning Equivalent Hearing Under            
          Section 6320 and/or 6330 for taxable years 1991, 1993, and 1994.            
          The notice and decision letter upheld the filing of notice of tax           
          lien against the deceased Mr. Deese for the respective  relevant            
          years.                                                                      
               On July 19, 2006, the petition was timely filed.  Ms. Deese,           
          then residing in Georgia, signed the petition as “Personal                  
          Representative for Bonnie W. Deese (deceased)”.2  On September 5,           
          2007, respondent filed his motion for summary judgment.  On                 
          September 6, 2007, we ordered petitioner to file a response to              



               2 The petition states that it is with respect to                       
          petitioner’s taxable years 1990, 1991, 1992, 1993, and 1994.  By            
          Order dated Dec. 29, 2006, this Court granted respondent’s motion           
          to dismiss for lack of jurisdiction and to strike as to taxable             
          years 1991, 1993, and 1994, on the ground that petitioner had               
          failed to make a timely request for a sec. 6320 hearing within              
          the statutorily mandated period after respondent sent the first             
          notice of tax lien filing for those years on Aug. 21, 2002.                 
          Consequently, only taxable years 1990 and 1992 remain at issue.             






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