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On October 20, 1997, the IRS mailed correspondence to the
Chans consisting of final Statements of Account and bills for
examination adjustments for the Chans’ taxable years 1992 and
1993. Petitioner first was informed of the amount of interest
computed with respect to the deficiencies in the Chans’ income
taxes on this occasion.
Petitioner filed a Form 433-F, Collection Information
Statement, on November 26, 1997, requesting to pay the amounts
owed in installments of $400 per month. On January 26, 1998, the
IRS sent a letter to petitioner rejecting his request for payment
by installment. After receiving a letter from petitioner
concerning the rejection of his installment agreement request,
the IRS, on March 18, 1998, consented to allow the Chans to pay
their tax liability in $400 monthly installments.
On April 11, 1998, petitioner sent to the IRS a letter
requesting waiver of interest and penalties with respect to the
adjustments for the taxable years 1992 and 1993. On April 28,
1998, the IRS prepared a Notice of Federal Tax Lien concerning
the unpaid income tax deficiency assessments. On May 4, 1998,
the IRS sent a letter to petitioner notifying him that before any
request for penalty abatement could be entertained by the IRS,
petitioner would have to pay the entire amount of tax owed. On
November 14, 1998, petitioner filed Forms 843, Claim for Refund
and Request for Abatement, seeking interest and penalty
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