- 4 -
Petitioners filed petitions with the Court for the 1996 and
1997 tax years, and the docketed cases were assigned to an IRS
Appeals officer. On July 19, 1999, petitioners wrote to the
Appeals officer and submitted documentation to support their
gambling losses. On July 29, 1999, the Appeals officer wrote to
petitioners informing them that she accepted the documentation
for gambling losses and would allow the losses as itemized
deductions up to the amount of petitioners’ gambling winnings.
She also agreed to waive penalties if petitioners agreed to the
gambling adjustments and to the adjustments for their Social
Security income for both years.
Petitioners did not reach a settlement with the Appeals
officer, and the 1996 and 1997 cases were transferred to the IRS
Chief Counsel’s office in Philadelphia, Pennsylvania, for trial
preparation. The cases were settled by the IRS trial attorney on
the same terms as the offer made by the Appeals officer, and
decisions were entered on September 23, 1999, for tax year 1996
and October 4, 1999, for tax year 1997. Petitioners are
currently paying their 1996 and 1997 tax liabilities through an
installment agreement. The penalties listed in petitioners’
monthly statement from the IRS are failure to pay penalties.
Petitioners contend that they are entitled to have their
interest abated because the IRS delayed adjusting their 1996 and
1997 income tax liabilities. Mr. Kupersmit argued at trial that
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011