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assessed petitioners’ unpaid liability for 1996 (including a
penalty and interest). An NFTL was filed on August 31, 1998,
with respect to this assessment.
Petitioners filed their 1997 Form 1040 on April 15, 1998,
with a balance due of $4,395. Petitioners did not submit this
balance with their return. On May 18, 1998, the Commissioner
assessed petitioners’ unpaid tax liability for 1997 (including
penalties and interest). An NFTL was filed on November 24, 1998,
with respect to this assessment.
Mr. Hinterleitner had unpaid employment taxes for 1994.
These taxes (including interest) were assessed on February 3,
1997. An NFTL was filed on July 29, 1998, with respect to this
assessment.
In 1999, petitioners entered into an installment agreement
to make payments on their 1995 through 1997 income tax
liabilities and on Mr. Hinterleitner’s employment tax liabilities
for 1994.
In June 2000, petitioners wanted to refinance some real
property but were unable to do so without addressing the
outstanding NFTLs. Petitioners met with Revenue Agent Ruben
Villareal (Mr. Villareal) on June 1, 2000, to discuss the
refinancing and NFTLs. Pursuant to Mr. Villareal’s suggestion,
petitioners filed with the Commissioner Forms 843, Claims for
Refund and Request for Abatement, for 1995, 1996, and 1997.
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Last modified: May 25, 2011