Winston O. and Paulet P. Smith - Page 2

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          Collection Waiver, relating to petitioners’ 1982, 1983, 1986, and           
          1987 tax liabilities.  The Form 900 extended, until December 31,            
          2004, the period of limitations relating to collection of                   
          petitioners’ tax liabilities.  On January 1, 2000, petitioners              
          and respondent executed a second installment agreement.                     
          Petitioners later defaulted on the second agreement.                        
               On May 8, 2001, petitioners met with Revenue Officer                   
          Shoesmith, with whom they discussed a possible offer-in-                    
          compromise and another installment agreement.  Shoesmith                    
          recommended to her supervisor that respondent reject these                  
          collection alternatives because she believed that, among other              
          things, petitioners failed to file returns relating to numerous             
          years, had withheld information relating to their wherewithal to            
          pay, and were trying to avoid paying their taxes.                           
               On July 2, 2001, respondent sent petitioners a Notice of               
          Defaulted Installment Agreement Under IRC 6159(b) and a Notice of           
          Intent to Levy Under IRC 6331(d) relating to their 1982, 1983,              
          1986, 1987, and 1999 unpaid tax liabilities.  Petitioners’ 1999             
          tax liability has been satisfied.                                           
               On July 16, 2001, respondent received petitioners’ Form                
          12153, Request for a Collection Due Process Hearing, in which               
          petitioners contended that their outstanding tax liability                  
          relates only to 1999, they have been making installment payments,           
          they provided updated financial information, respondent’s revenue           






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