- 2 - Background Petitioner submitted to the Internal Revenue Service Forms 1040, U.S. Individual Income Tax Return, for 1999, 2000, 2001, 2002, 2003, 2004, and 2005. Petitioner listed only zeros on the Forms 1040 for 1999, 2000, 2001, 2002, 2003, 2004, and 2005-- e.g., listing zero income and zero tax due. Respondent mailed petitioner statutory notices of deficiency for 1999, 2000, and 2003. Petitioner received the notices of deficiency for 1999, 2000, and 2003. Petitioner, however, did not petition the Court regarding the notices of deficiency for 1999, 2000, and 2003. On September 15, 2004, respondent sent petitioner a Final Notice, Notice of Intent to Levy and Notice of Your Right to a Hearing with respect to petitioner’s 1999, 2000, and 2003 taxable years (notice of levy). On or about October 14, 2004, petitioner sent respondent a Form 12153, Request for a Collection Due Process Hearing (hearing request). On the hearing request, petitioner wrote that “I will explain at the collection due process hearing” why she did not agree with the notice of levy; she did not list any years in the space provided for “taxable years”. Petitioner did not propose any collection alternatives. On January 11, 2005, Appeals Team Manager Leland J. Neubauer sent petitioner a letter advising her that the Oklahoma CityPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011