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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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Last modified: March 27, 2008