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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,
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