- 5 - be abated and the installment agreement could be entered into the computer records. By entering into the installment agreement, petitioners were able to secure release of the wage levy. Petitioners have continued to make payments of $1,000 per month under the installment agreement. During the summer of 1998, Cooper continued to have discussions with the Special Procedures Branch concerning the abatement of the 1983 tax liability and the pension plan. On August 17, 1998, Special Procedures instructed Cooper to obtain additional information regarding the pension plan. On September 11, 1998, petitioners’ attorney forwarded the pension plan information and an attached letter to Cooper. The letter from petitioners’ attorney explained his understanding of the effect of the installment agreement, which was that the IRS would not commence additional collection procedures so long as the Morgans complied with the terms of the installment agreement. Petitioners were sent a Final Notice of Intent to Levy and Notice of Your Right to a Hearing on December 27, 1999. The taxes owed with penalties and interest, as set forth in the final notice, were $360,629.03, $309,937.93, and $379,581.83, for 1981, 1982, and 1983, respectively. Petitioners filed a Request for a Collection Due Process Hearing on January 26, 2000. The hearing was held in or about September 2000. At the hearing, petitioners argued that the 1983 tax was discharged in bankruptcy and thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011