- 3 -
perhaps having something to do with petitioner’s health,2 after
correspondence with petitioner in August 1997, collection
activity with respect to petitioner’s 1995 tax liability was
suspended until sometime in 2003.
In October 2003 respondent contacted petitioner regarding
her 1995 liability, and following a series of contacts and
correspondence, on March 9, 2005, respondent issued a final
notice of intent to levy with respect to that liability. In
response to that notice, petitioner requested an administrative
hearing. In her request for the administrative hearing
petitioner stated:
I disagree with the Notice of Levy for the following
reasons:
1. I do not owe taxes for 1995.
2. I sent the 1995 payment in the amount of $2,231
along with my tax return to the IRS at Atlanta, GA
39901, in August 1996.
3. An Affidavit of 1995 Payment is attached.
The affidavit referenced in her request predates the request and
apparently had been submitted previously to respondent. In that
affidavit petitioner stated that the $2,231 income tax liability
reported on her 1995 return was fully paid with that return. A
fair reading of the affidavit suggests that the payment was made
by a check that “was sent in the same envelope as * * * [her]
return.”
2 Petitioner was involved in some sort of accident in 1995
that resulted in her being disabled for an unspecified period.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: November 10, 2007