Donald R. Cooley and Cathy A. Cooley - Page 15

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               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.”                                                                 








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