- 5 - write “CIVPEN” on each payment because they disputed the TFRP liabilities, they did include respondent’s payment voucher with each payment. Respondent applied these payments to the TFRP liabilities.4 On August 28, 1998, Mr. Lah attended an IRS problem-solving day in which he argued that his income tax liabilities for the years in issue should be abated because the payments made pursuant to the installment agreement were intended to pay off these income tax liabilities. The IRS revenue agent reviewed the payments made by petitioners and ensured that all checks designated for application to the income tax liabilities for the years in issue were applied, including the August 12, 1996, payment. On October 26, 1998, petitioners filed a Form 843, Claim for Refund and Request for Abatement, for a refund of the payments made pursuant to the installment agreement that respondent applied to the TFRP liabilities. Respondent disallowed this claim. On August 24, 2001, respondent sent a Final Notice of Intent to Levy and Notice of Your Right to a Hearing for the years in issue. The taxes owed with penalties and interest, as set forth 4 As a result of the bankruptcy proceeding, the statute of limitations period to collect the TFRP liabilities expired on Oct. 26, 1998, for Mr. Lah, and Dec. 7, 1998, for Mrs. Lah. See sec. 6503(h) (suspending the running of the period of limitations during the period of bankruptcy).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011