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which the PS Form 3877 in question showed was mailed to him by
certified mail on May 5, 1999.
Respondent mailed to petitioners, and petitioners received,
a notice dated October 4, 1999, relating to petitioners’ taxable
year 1997 (October 4, 1999 notice). That notice stated in
pertinent part:
WE CHANGED YOUR ACCOUNT
THE CHANGE(S) BELOW RESULTED FROM AN EXAMINATION
OF YOUR TAX RETURN SHOWN ABOVE [FORM 1040 FOR TAX
PERIOD DECEMBER 31, 1997]. PLEASE SEE YOUR COPY OF THE
EXAMINATION REPORT FOR A DETAILED EXPLANATION OF THE
CHANGES.
* * * * * * *
STATEMENT OF ACCOUNT
ACCOUNT BALANCE BEFORE EXAMINATION ACTION NONE
INCREASE IN TAX BECAUSE OF
EXAMINATION ACTION $64,864.00
CIVIL PENALTY ADDED 12,972.80
INTEREST CHARGED 7,745.98
DECREASE IN INTEREST PREVIOUSLY ALLOWED 57.03
AMOUNT YOU NOW OWE $85,639.81
PLEASE PAY THE FULL AMOUNT BY OCT. 25, 1999. IF
YOU’VE ALREADY PAID YOUR TAX IN FULL OR ARRANGED FOR AN
INSTALLMENT AGREEMENT, PLEASE DISREGARD THIS NOTICE.
On November 8, 1999, respondent mailed a notice to petition-
ers with respect to their taxable year 1997 (November 8, 1999
notice). That notice stated in pertinent part:
We previously wrote to you about your unpaid account,
but you haven’t contacted us about it. Penalties and
interest on the unpaid balance are continuing to in-
crease. Please pay the amount you owe now. * * *
In response to the November 8, 1999 notice, on November 11,
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