- 2 - FINDINGS OF FACT On April 1, 1999, John and Donna Ringgold (petitioners) executed and sent respondent Form 4549-CG, Income Tax Examination Changes, in which petitioners agreed to the immediate assessment and collection of additional tax liabilities for 1995 and 1997. The form set forth deficiencies, additions to tax, penalties, and interest through April 21, 1999, totaling $20,100.33. In an accompanying letter, petitioners offered to settle their entire tax liability for $12,803.00 (i.e., the amount of the balance due excluding additions to tax, penalties, and interest) and requested 60 days from April 15, 1999, to secure the necessary funds. Several weeks later, Mr. Ringgold asked respondent’s auditor whether the terms of his letter had been accepted. The auditor responded affirmatively, but was under the mistaken impression that petitioners’ letter was merely a request for a short-term extension of time to pay the liability. On April 6, 1999, the auditor prepared and sent to petitioners Form 433-D, Installment Agreement, for $20,100.33 (i.e., the entire amount of the liability per the audit report), put a hold on the collection activity for 120 days, and closed the file as “agreed”. On June 7, 1999, respondent made an additional assessment, and on September 6, 2000, sent petitioners a Notice of Federal Tax LienPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011