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Respondent assessed the tax liabilities shown on
petitioners’ Forms 1040 for 1995, 1996, and 1997 and assessed
additions to tax under section 6651(a)(1) for late filing,
section 6651(a)(2) for failure to pay tax, and section 6654(a)
for failure to make estimated tax payments for each year. As of
June 9, 1999, petitioners still owed tax for each year. On that
date, respondent sent to petitioners a notice of intent to levy
that advised petitioners of their right to a hearing under
section 6330. Petitioners requested the hearing.
At the hearing conducted by an Appeals officer, petitioners
requested that they be permitted to enter into an installment
agreement as an alternative to collection by levy. Petitioners
also requested abatement of the additions to tax based on Adams’s
illness from diabetes during the years in which the returns were
due. To determine whether petitioners were financially able to
make monthly payments under the installment agreement to pay
fully their outstanding tax liabilities, the Appeals officer
requested, and petitioners provided, Form 433-A, Collection
Information Statement for Individuals, dated March 1, 2000.
According to petitioners’ statement, their monthly expenses
exceeded their total income. To support their request for
abatement of penalties, petitioners submitted the medical file of
Adams concerning his diabetes that petitioners claimed disabled
him from October 1996 through March 20, 2000.
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Last modified: May 25, 2011