Linda L. Pool - Page 2

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                                     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 City                






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