Carol A. Black and William R. Adams - Page 3

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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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