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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.
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