- 3 -
afterwards informed them that it had received only an original
Form 1040 income tax return for 1996 on March 13, 1998.
In July of 1998, petitioners prepared and mailed a Form 1040
for 1997. On this return, petitioners noted that they had
requested the $1,160 from their amended 1996 income tax return be
applied to their 1997 tax liability. The IRS did not receive
this return.
On August 16, 1999, the IRS issued a notice of income tax
delinquency (notice of delinquency) for 1997 to petitioner Jo
Grandelli individually under her maiden name and to an address
where petitioners had not resided since before they filed their
1996 return. Petitioners did not receive this notice of
delinquency.
On March 9, 2002, the IRS issued a Letter 1058, Notice of
Intent to Levy and Notice of Your Right to a Hearing, to Mrs.
Grandelli under her maiden name at petitioners’ correct address,
which was the address provided on petitioners’ 1996 return that
the IRS received. The notice was of intent to levy to collect an
assessment of a deficiency on Mrs. Grandelli’s individual account
for 1997.
Petitioners learned through correspondence with the IRS that
it had not received their amended 1996 return or any return for
1997. Petitioners mailed a copy of their amended 1996 return to
the IRS’s Taxpayer Advocate Service in Philadelphia on May 3,
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: March 27, 2008