- 5 - On December 26, 1995, petitioners filed a petition for redetermination with the Court. The petition includes allegations that the amount in dispute is $8,692.79, that petitioners paid the tax on July 18, 1994, and that respondent computed the interest incorrectly. On February 20, 1996, petitioners paid $3,240.60 which respondent applied against the $8,692.79 assessment for section 6621(c) interest that respondent assessed against petitioners on October 23, 1995. On June 24, 1996, petitioner filed a Motion to Restrain Assessment and Collection attaching thereto a notice of intent to levy which respondent issued to petitioners on June 10, 1996, demanding payment in the amount of $5,926.35 for the taxable year 1986. Petitioner's motion was called for hearing in Washington, D.C., on August 28, 1996. Counsel for respondent appeared at the hearing and was granted leave to file an objection to petitioner's motion. Although petitioner did not appear at the hearing, he did file three written statements with the Court pursuant to Rule 50(c).2 Reading petitioner's written statements together, petitioner contends that the $3,240.60 that petitioners 2 After the hearing, petitioner filed a response to respondent's memorandum of law in support of respondent's objection to petitioner's motion to restrain assessment and collection.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011