- 2 - 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 DeclarationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011