Angelo N. & Jo E. Grandelli - Page 3




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          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,               







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