- 15 - Statutory Notice of Deficiency issued on April 4, 2000, are not part of this balance owed. This balance owed shown on the L-1058 was as of 03/09/2000 and was from the taxpayers’ voluntarily filed original and amended returns that had been processed by the Service. As to petitioners’ contention that the amount due had not been determined, the Appeals officer said: “The amount due, as shown on the L-1058 dated 03/09/2000, had been determined from their voluntarily filed original and amended returns.” On July 5, 2000, after receiving the notice of deficiency, petitioners filed a petition in this Court which was filed as docket No. 7464-00. In their petition, petitioners contended: The tax assessed by the Internal Revenue Service is incorrect and overstated. Taxpayer believes that the records generated by the investigation of the Internal Revenue Service would reveal that said assessment is premised upon an overstatement of income in taxpayers amended returns. Further, taxpayer does not believe that the civil penalties assessed him under IRC Section 6663(a) are applicable to all of the additional reported income in the years proposed. On September 7, 2000, after receiving the notices of determination, petitioners filed a petition in this Court, which was filed as docket No. 9452-00L. In their petition, petitioners contended: “The [taxpayers] have petitioned the [T]ax [C]ourt for the above listed tax years to determine the correct tax liability, IRS has examined the years in question. Prior to the start of collection action, the correct liability should be determined.”Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011