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taxable years 1992, 1993, 1994, 1996, 1997, 1998, and 1999.
As of April 22, 2002, petitioners’ total unpaid income tax
liability, including penalties and interest, for the foregoing
taxable years was $605,330.
On April 22, 2002, respondent issued to petitioners a letter
entitled “FINAL NOTICE–-NOTICE OF INTENT TO LEVY AND NOTICE OF
YOUR RIGHT TO A HEARING” relating to petitioners’ unpaid income
tax liabilities plus penalties and interest for the
aforementioned years. Thereafter, on April 26, 2002, petitioners
sent Form 12153, Request for a Collection Due Process Hearing, to
respondent’s Appeals Office. Petitioners disagreed with
respondent’s decision to levy and indicated they were unable to
pay the assessments in full at that time. Petitioners also
assured the Appeals Office that they would use the proceeds from
the sale of two listed real estate properties to pay respondent
in the future.
Petitioners later submitted personal financial information
that reflected $343,842 in liquid assets and $811,408 equity in
real estate.
Petitioners’ counsel contacted the respondent’s Appeals
Office and requested a $1,500 monthly installment agreement under
section 6159. Petitioners also offered to pay the balance of the
liability when they managed to sell some of their properties.
After reviewing petitioners’ financial information, respondent
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