James J. Crisan and Veronica L. Crisan - Page 2

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          determination).1  The issue for decision is whether there was an            
          abuse of discretion in the determination that collection action             
          could proceed for 1998 and 1999 (years in issue).                           
                                     Background                                       
               All of the facts have been stipulated.  The stipulated facts           
          and the attached exhibits are incorporated herein by this                   
          reference.                                                                  
               Petitioners resided in Warren, Ohio, at the time they filed            
          the petition.  As of May 15, 2003, petitioners owed tax                     
          liabilities of $25,398 and $6,683 for 1998 and 1999,                        
          respectively, including additions to tax and interest.                      
               The tax liabilities for the years in issue resulted from               
          petitioners’ failure to make sufficient quarterly payments of               
          estimated taxes to cover the taxes that resulted from bonuses               
          received by Mr. Crisan.  Petitioners proposed an installment                
          agreement with monthly payments of $100.  Respondent rejected               
          this proposal as “unrealistic and unreasonable” given the size of           
          the tax liabilities.                                                        
               When no installment payment amount could be agreed to by the           
          parties, respondent issued each petitioner a Final Notice of                
          Intent to Levy and Notice of Your Right to a Hearing on January             
          25, 2001.  On February 20, 2001, petitioners sent respondent a              


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the years in issue.                 
          Amounts are rounded to the nearest dollar.                                  




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