John D. and Kim M. Hinterleitner - Page 3

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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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