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officer acted improperly and maliciously, and they were taking
steps to pay their outstanding tax liabilities.
By letter dated July 26, 2001, Shoesmith indicated that
petitioners’ case was being sent to respondent’s Appeals Office,
and petitioners had not submitted requested financial
information. On July 31, 2001, respondent received a letter in
which petitioners contended that they substantially complied with
respondent’s requests for financial information and had
legitimate reasons for their failure to respond more fully.
By letter dated October 11, 2001, respondent sent
petitioners literal transcripts relating to the years at issue.
The transcripts verified the amount and timely assessment of
petitioners’ tax liabilities relating to all years in issue
(i.e., 1982 on December 8, 1986, 1983 on September 29, 1987, and
1986 and 1987 on July 25, 1988).
On October 17, 2001, Settlement Officer Salinger and
petitioners participated in a section 63301 hearing.
Petitioners contended that the period of limitation relating to
collection (collection period) expired with respect to
petitioners’ 1982 and 1983 tax liabilities and attempted to
dispute such underlying liabilities (i.e., presentation of
evidence to substantiate entitlement to unspecified deductions).
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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Last modified: May 25, 2011