-3-
hearing with respondent’s Office of Appeals (Appeals) to discuss
the proposed levy.
On September 13, 2000, petitioner requested the referenced
hearing. Later, Appeals held that hearing with petitioner by
telephone. At the hearing, petitioner did not dispute the
existence or amount of its tax liabilities for 1997 and 1998.
The only issue raised by petitioner was that it needed more time
to pay its tax liabilities through an installment agreement.
During the hearing, the Appeals officer reviewed the
transcripts of petitioner’s accounts for 1992, 1994, 1995, 1997,
1998, 2000, and 2001 and discerned that petitioner had not filed
its 1992, 1994, 1995, and 1997 Forms 1120, or its Forms 941 for
the second and fourth quarters of 2001. The Appeals officer also
discerned that petitioner had not made any estimated payments for
2001 or payroll deposits for the second and fourth quarters of
2001. The Appeals officer reviewed petitioner’s financial
records and discerned: (1) Petitioner had commingled its funds
with the funds of a related corporation, and (2) petitioner’s
corporate funds had been used to pay the personal expenses of
petitioner’s shareholders.3 These personal expenses included
automobile insurance for all vehicles used in their household,
housecleaning, children’s college expenses, checks to children,
3 As of 1999, petitioner was owned equally by Shirley
Gorospe and Conrad T. Gorospe.
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