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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 that
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Last modified: May 25, 2011