Robert and Ines M. Gillespie, et al. - Page 5




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          taxes, and, on May 9, 2001, respondent issued to the trustee a              
          notice of deficiency with respect to the trust’s 1999 Federal               
          income tax.  No petitions were filed in this Court in response to           
          any of those notices of deficiency, and respondent properly                 
          assessed the deficiencies determined in each case.                          
          Notices                                                                     
               On March 22, 2004, respondent sent to the Gillespies with              
          respect to their 1999 tax year a Final Notice – Notice of Intent            
          to Levy and Notice of Your Right to a Hearing (final notice).  On           
          March 29, respondent sent to the trustee with respect to the                
          trust’s 1996 through 1999 tax years a final notice.                         
               On April 9, 2004, respondent sent to the Gillespies with               
          respect to their 1996 through 1999 tax years a Notice of Federal            
          Tax Lien Filing and Your Right to a Hearing Under IRC 6320                  
          (NFTL).  On that same date, respondent sent to the trustee with             
          respect to the trust’s 1996 through 1999 tax years an NFTL.                 
          Responses and Hearing                                                       
               On April 27, 2004, in response to the final notice they had            
          received, the Gillespies filed with Appeals an Internal Revenue             
          Service (IRS) Form 12153, Request for a Collection Due Process              
          Hearing.  On the Form 12153, the Gillespies stated their                    
          disagreement with the final notice as follows:  “We disagree with           
          the determination of the taxes and additions owed, and the                  
          calculations of the amounts due, if any.”  On May 13, 2004, in              







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