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Unless otherwise indicated, all section references are to
the Internal Revenue Code for the relevant year. Amounts are
rounded to the nearest dollar.
Background
All of the facts have been stipulated. The stipulated facts
and the attached exhibits are incorporated herein by this
reference.
Petitioners resided in Port Clinton, Ohio, at the time they
filed their petition. At the time of filing the petition,
petitioner Robert M. Galvin (Mr. Galvin) was 75 years old and in
poor health. Mr. Galvin had practiced law for 26 years.
Petitioners entered into six installment agreements to pay
their unpaid tax liabilities on which they defaulted by failing
to make required payments and to timely pay other tax
liabilities.
On February 22, 2000, petitioners submitted to respondent
Form 433-A, Collection Information Statement for Individuals.
Based upon the income and expense information provided by
petitioners, respondent determined that $790 per month could be
paid. Petitioners rejected the proposal.
On May 5, 2000, a Final Notice--Notice of Intent to Levy and
Notice of Your Right to a Hearing was sent to petitioners. The
taxes owed, as set forth in the final notice, including additions
to tax, penalties, and statutory interest, were as follows:
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Last modified: May 25, 2011