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years in issue, petitioner worked as an engineer technician.
Petitioner separated from Mr. Hopkins in December 1996, and they
remained separated at the time of trial.
In March 1997, petitioner and Mr. Hopkins’s home was
foreclosed upon as the result of a late mortgage payment. Mr.
Hopkins withdrew money from his section 401(k) account early in
1997.
Petitioner and Mr. Hopkins filed joint Federal income tax
returns for tax years 1995 and 1996 but did not pay all the tax
reported thereon. The unpaid tax liabilities resulted from
underwithholding from wages attributable to both petitioner and
Mr. Hopkins. Respondent accepted the returns as filed and
assessed tax as reported by petitioner and Mr. Hopkins.
Respondent issued to petitioner a Final Notice of Intent to
Levy and Notice of Your Right to a Hearing Under IRC 6330 (notice
of intent to levy) dated February 7, 2004, for tax years 1994 and
1995. Respondent filed a notice of Federal tax lien against
petitioner and Mr. Hopkins on April 19, 2004, for tax years 1994,
1995, and 1996 and issued them a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under IRC 6320 on April 22,
2004.
On May 10, 2004, petitioner submitted a Form 12153, Request
for a Collection Due Process Hearing, and attached a Form 8857,
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