Donald R. Cooley and Cathy A. Cooley - Page 9

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         and sentenced him to 4 months' incarceration at the Alpha House,             
         a halfway house located in Springfield, Missouri, followed by 2              
         years of supervised release.                                                 
               On April 4, 2000, petitioners received their notice of                 
         deficiency for their 1989, 1990, 1991, 1992, and 1993 taxable                
         years.                                                                       
               On June 27, 1999, respondent issued a Final Notice - Notice            
         of Intent to Levy and Notice of Your Right to a Hearing, for                 
         petitioners’ 1989, 1990, 1992, 1993, and 1996 taxable years.  The            
         account summary of the final notice indicated that respondent was            
         trying to collect the following amounts:                                     
         Year    Assessed Balance1     Statutory Additions          Total             
         1989       $9,664.88                $0.00               $ 9,664.88           
         1990       8,129.85            1,895.48                 10,025.33            
         1992       1,968.42            396.69                   2,365.11             
         1993       0.00                2,016.71                 2,016.71             
         1996       2,203.02                 332.19              2,535.21             
         1The assessed balances for 1989, 1990, 1992, and 1993 consists               
         entirely of accrued interest.  The assessed balance for 1996                 
         includes some of the original tax liability, penalties, and                  
         interest.                                                                    
               On July 23, 1999, petitioners filed a Request for a                    
         Collection Due Process Hearing (request), for their 1989, 1990,              
         1992, 1993, and 1996 taxable years.  In their request petitioners            
         contended: “The tax liability figures are still incorrect based              
         on inaccurate figuring of tax amounts paid and failure to credit             
         excess tax payments towards amounts owed on other tax years.”                
         Petitioners also raised a section 6015 defense with respect to               





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