- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code as applicable to the years in issue. Hereinafter, references to petitioner in the singular are to petitioner Roy Eliason. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioners resided in O’Fallon, Missouri. Petitioners’ undisputed and unpaid Federal income tax liabilities including penalties and interest, as of October 1, 2001, total $1,902 for 1994 and $5,254 for 1995. On May 22, 1999, respondent mailed to petitioners a notice of intent to levy and a notice of petitioners’ right to a collection hearing with respondent’s Appeals Office relating to petitioners’ income tax liabilities for 1994 and 1995. On June 14, 1999, respondent received from petitioners a request for a collection hearing with respondent’s Appeals Office. On May 20, 2000, in connection with the above request by petitioners for a collection hearing, petitioners submitted to respondent’s Appeals Office a financial statement showing with respect to petitioners’ monthly income and expenses a net income of $1,914. After adjustments were made by respondent’s Appeals Office increasing the amount of petitioners’ monthly expenses,Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011