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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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