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Respondent issued notices of final partnership
administrative adjustments (FPAAs) to DGE 83-3 for its 1983
through 1985 taxable years.6 After completion of the
partnership-level proceedings, respondent determined deficiencies
in petitioners’ income tax for their 1980 through 1985 tax
years.7
On February 6, 2003, respondent issued petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice). The final notice included petitioners’
outstanding tax liabilities for 1980 through 1985, 1989, and
1990.
On February 21, 2003, petitioners submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioners argued
that the proposed levies were inappropriate, that an offer-in-
compromise should be accepted, and that Mrs. Freeman was entitled
to innocent spouse relief under section 6015.
On November 14, 2003, petitioners’ case was assigned to
Settlement Officer Linda Cochran (Ms. Cochran). Ms. Cochran
scheduled a telephone section 6330 hearing for March 31, 2004.
Petitioners’ representative, Terri A. Merriam (Ms. Merriam),
6 The FPAAs and other information specific to DGE 83-3’s
partnership-level proceedings are not in the record.
7 The details regarding the adjustments made to
petitioners’ tax liability for 1989 and 1990 are not in the
record.
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Last modified: May 25, 2011