- 5 - I also reclassified the claim from an Equivalent Hearing to a Collection Due Process Hearing. However, you did not submit an amended return for 1996, nor did you return the Installment Agreement form. These were your alternatives to the proposed levy action. Without your cooperation, the determination of the ACS function is being upheld. The case file will be returned to them for all appropriate action. After receiving the notice of determination, on the advice of the Appeals officer, petitioners made payments on their tax liability to respondent. Mr. Brown sent respondent seven checks and one money order totaling $850. Petitioners’ balances for the years in issue were: Year As of Outstanding Balance 1995 8/13/2001 $4,127.50 1996 10/22/2001 2,773.44 1997 6/4/2001 108.17 When this case was called for trial, petitioners failed to appear. The Court set the case for recall during the second week of the calendar in order to give petitioners an opportunity to have their day in Court. Mr. Brown appeared at the recall. OPINION Petitioners do not dispute that the amount of the tax, additions to tax, and interest assessed are correct. Pursuant to the stipulations and deemed admissions, petitioners have conceded their claim for interest abatement. Petitioners argue that respondent should accept less than the full amount of their liabilities because the additions to tax and interest are too much for petitioners to pay on Mr. Brown’sPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011