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On October 25, 1999, approximately 1 month after receiving
petitioners’ 1997 return, respondent assessed additions to tax
pursuant to section 6651(a)(1) and (2) for 1997.
Petitioners timely requested a hearing pursuant to section
6330 with respect to a notice of intent to levy regarding
petitioners’ income tax liabilities for 1995, 1996, and 1997.4
An Appeals officer and Mr. Brown had a section 6330 hearing
(hearing) via telephone. At the hearing, petitioners did not
dispute their underlying liabilities. At the hearing,
petitioners requested that interest be abated and respondent
accept less than the full amount owed (i.e., not seek to collect
the additions to tax and interest). Petitioners and the Appeals
officer discussed alternatives to collection by levy.
On February 28, 2001, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 to petitioners regarding their 1995, 1996, and 1997
tax years (notice of determination). In the notice of
determination, respondent determined petitioners were entitled to
a partial abatement of the assessed section 6651(a)(2) addition
to tax and the associated interest for 1996 and 1997.
Respondent’s determination also provided:
4 Neither petitioners’ request for a hearing nor the notice
of intent to levy was made part of the record because
respondent’s files were destroyed along with World Trade Center
Building No. 7 in the Sept. 11, 2001, terrorist attack on the
United States.
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Last modified: May 25, 2011