Charles R. Godwin et al. - Page 10

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          tax under section 6654(a) for failing to pay estimated taxes,               
          section 6651(a)(1) for late filing of their 1997 return, and                
          section 6651(a)(2) for late payment of their tax liability.                 
               On October 24, 1999, respondent sent petitioners a Final               
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing with respect to their unpaid 1997 income tax liability,             
          additions to tax, and interest.  By letter dated November 4,                
          1999, petitioner sent respondent a Form 12153, Request for a                
          Collection Due Process Hearing.                                             
               By November 24, 1999, during the pendency of petitioners’              
          section 6330 hearing, petitioners had paid the remaining balance            
          of the unpaid 1997 income tax liability shown on their return;              
          however, the record does not contain the exact date or dates of             
          petitioners’ payments.  At the hearing, petitioners contested               
          their liability for unpaid additions to tax and interest.                   
          Petitioners did not raise any collection issues other than that             
          they had tried to compromise the entire liability for tax,                  
          additions, and interest with an offer to pay $100,000.  The                 
          Appeals officer at the hearing upheld the assessment of the                 
          additions and accrued interest and sustained respondent’s levy.             
               On August 7, 2001, respondent sent petitioner by certified             
          mail a notice of determination under section 6330.  On August 15,           
          2002, respondent sent petitioner by certified mail a supplemental           
          notice of determination under section 6330.  On August 15, 2002,            






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