- 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