Christine A. Dormer - Page 4

                                        - 4 -                                         
               Thereafter, for reasons not otherwise elucidated, respondent           
          on July 23, 2001, abated $3,605 of the assessed tax and $579.93             
          of the interest, leaving a balance of tax due in the amount of              
          $6,997.  Respondent at the same time assessed an addition to tax            
          pursuant to section 6651(a) of $69.97.  A further notice of                 
          balance due was also sent on that date.                                     
               In September of 2001, respondent issued to petitioner                  
          notices of intent to levy with respect to the 1998 year.  A face-           
          to-face hearing was then held on April 11, 2002, between                    
          petitioner, Mr. Patel, and Appeals Officer Judith Hornstein                 
          (Ms. Hornstein).  At the conference, the parties discussed a                
          potential resolution of the collection dispute, which involved a            
          proposed 25-percent reduction in the tax due from petitioner for            
          1998 and an abatement in full of the section 6662 penalty.                  
          Significantly, neither interest nor the addition to tax under               
          section 6651 was ever discussed at the hearing.                             
               The parties did not agree to a settlement at the April 11,             
          2002, hearing, but on May 20, 2002, Mr. Patel sent to                       
          Ms. Hornstein a letter advising that petitioner wished to resolve           
          the matter for the amount discussed at the April 11 meeting.  The           
          letter continued:                                                           
                    Ms. Dormer has borrowed the funds necessary to pay                
               the amount in a lump sum payment.  However, before we                  
               make the payment, we will need you to confirm that the                 
               $300.00 refund authorized by President Bush as well as                 
               Ms. Dormer’s 2001 refund has been garnished and applied                
               by the Internal Revenue Service.  We will then need to                 





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011