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discretion by sustaining a proposed levy to collect petitioners’
unpaid income tax liabilities for 1999 and 2000.
Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure. All amounts
have been rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time that the petition in this case was filed, petitioners
resided in Cape Coral, Florida.
Background
Petitioners filed their joint Federal income tax return for
1999 on or about October 15, 2000, and their joint Federal income
tax return for 2000 in October 2001 showing balances due. As of
July 17, 2002, petitioners’ unpaid income tax liabilities for
1999 and 2000, including accruals of interest and penalties,
exceeded $385,000 and $64,000, respectively.
In March 2001, petitioners retained a certified public
accountant, David B. McKinnon (McKinnon), to represent them
before the Internal Revenue Service (IRS) in connection with the
collection of their tax liabilities. On or about March 28, 2001,
petitioners filed a Form 2848, Power of Attorney and Declaration
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