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The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. Pursuant to section 6330(d),1 petitioners seek
review of respondent's determination to proceed with collection
of their tax liabilities of $548.41 for 1993 and $12,451.82 for
1997. The issue for decision is whether all amounts that are the
subject of respondent's collection action have already been paid
by petitioners.
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioners resided in Randolph Center,
Vermont.
Background
Petitioners' Federal income tax return for 1991 was filed on
March 6, 1995. Their return for 1992 was filed on June 27, 1995.
The returns for 1993 and 1994 were filed on January 16, 1996.
The 1995 tax return was filed April 10, 1997. The 1996, 1997,
and 1998 returns were filed timely, and the 1999 return was filed
on April 21, 2000. Petitioners submitted for 1991 a Form 1040X,
Amended U.S. Individual Income Tax Return, claiming a credit of
1Sec. 6330 was enacted as part of the Internal Revenue
Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.
105-206, sec. 3401, 112 Stat. 746. Sec. 6330 is effective with
respect to collection actions initiated more than 180 days after
July 22, 1998; i.e., after Jan. 18, 1999. See RRA 1998 sec.
3401(d), 112 Stat. 750.
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