John E. Hunter, II and Alma E. Hunter - Page 10

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          Hunters’ return as filed erroneously claimed only one exemption             
          on line 6d, but the computation assumed that they are entitled to           
          two exemptions.                                                             
               In December 2004, the Hunters timely filed a petition for              
          review of the notice of deficiency.                                         
               On March 18, 2005, respondent filed a motion to dismiss for            
          failure to state a claim upon which relief can be granted.  The             
          motion came on for hearing in Detroit, Michigan, on June 6 and              
          10, 2005.  The Hunters were present at the hearings.                        
          Respondent’s counsel and the Court explained the issue in the               
          case with respect to computation of the alternative minimum tax             
          and advised the Hunters to file an amended petition.  The Court             
          explained that the abatement of 2000 and/or 2001 taxes was simply           
          correction of a premature assessment of taxes that could later              
          be–-and in fact were--the subject of a timely notice of                     
          deficiency for 2001.  An amended petition was thereafter filed,             
          and the motion to dismiss was denied.                                       
               In March 2006, the Hunters sent respondent’s counsel a                 
          letter stating that the notice of deficiency contained an error             
          and should refer to line 6d, rather than to line 6e.                        
               Section 6320 provides that a taxpayer shall be notified in             
          writing by the Secretary of the filing of a notice of Federal tax           
          lien and provided with an opportunity for an administrative                 

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