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Mr. Cable also notified petitioner that he could pay this amount
in full or in monthly installments. Petitioner told Mr. Cable
that petitioner was unable to pay the balance in full at that
time or to enter into an installment agreement. Petitioner had
previously paid to the Commissioner at least $62,000 with respect
to subject year taxes by borrowing the money, and he was making
monthly payments on that debt while living on a fixed income.
On November 3, 1999, Appeals mailed to petitioner a Notice
of Determination Concerning Collection Action(s) under Section
6320 and/or 6330. The notice stated that petitioner’s Federal
income tax liability for the subject years was the $8,422.16
referenced above.
Petitioner petitioned the Court on December 2, 1999, to
review respondent’s determination. The petition contains no
allegation of error as to respondent’s determination. Petitioner
alleges in the petition that he has already paid his income tax
liability for the subject years (exclusive of interest and
penalties), that he lives on a “fixed income”, and that he has
“taken out a second mortgage to clear this debt, which has caused
me to be over-extended and behind with all my creditors”.
Petitioner requested in his petition that the Court waive the
$8,422.16. Petitioner asked the Court at trial, as an
alternative to waiving that amount, to allow him to meet with a
collection officer to discuss that amount.
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Last modified: May 25, 2011