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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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