- 2 - penalty should be imposed against petitioners. Respondent alleges that the section 6330 prerequisites have been met and that he should be allowed to proceed with collection of petitioners’ assessed and outstanding tax liability. With respect to the penalty, respondent contends that petitioners instituted this proceeding primarily for delay and that their position in the proceeding is frivolous and groundless. Petitioners’ objection to respondent’s motion for summary judgment was filed on December 10, 2002. In essence, petitioners contend that, although respondent has sent certain documents to them, those documents are not acceptable because they do not meet the standards that petitioners contend exist. Background Petitioners resided in Lakewood, California, at the time their petition was filed. Petitioners’ 1998 Federal income tax return was filed on April 15, 1999. Petitioners filed an income tax return on which they entered zeros in all pertinent boxes for the reporting of income, and they claimed a standard deduction and two exemptions. They also reported $7,726 of income tax withholding and, because they reported zero income, claimed an overpayment in the amount of the withheld tax. On that same return, petitioners reflected their occupations as “Graphic Artist” and “Dialysis”. Attached to petitioners’ return is aPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011