Christine A. Dormer - Page 5

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               hear from you as to whom the balance payment should be                 
               made payable to and where the payment should be sent.                  
               We will also need a release executed by the appropriate                
               representatives of the Internal Revenue Service                        
               confirming that once Ms. Dormer makes the lump sum                     
               payment that this matter will be resolved in its                       
               entirety and that Ms. Dormer will receive no further                   
               notices and no further collection attempts or lien                     
               efforts will be taken by the service.                                  
               Thereafter, according to the stipulation filed in the                  
          instant proceeding (and thereby incorporated into our findings):            
                    8.   On May 29, 2002, the parties agreed to a                     
               resolution of the Collection Due Process dispute                       
               whereby the Service would reduce the tax due from                      
               petitioner for the taxable year 1998 by 25%                            
               ($1,749.25), from $6,997.00 to $5,247.75, and after                    
               subtracting $1,003.00 in credits, the balance of tax                   
               due from petitioner for the taxable year 1998 was in                   
               the amount of $4,244.75.                                               
                    9.   The agreement also included abatement of the                 
               entire amount of penalty due from petitioner under                     
               I.R.C. � 6662 for the taxable year 1998.                               
               On the May 29, 2002, date, Ms. Hornstein mailed to                     
          Mr. Patel, as petitioner’s representative, a letter enclosing               
          copies of Form 12257, Summary Notice of Determination, Waiver of            
          Right to Judicial Review of a Collection Due Process                        
          Determination, and Waiver of Suspension of Levy Action, with the            
          following explanation:                                                      
               Enclosed are three copies of the Summary Notice of                     
               Determination.  Our agreed settlement is on the bottom                 
               of page two.  Please sign and return two copies of the                 
               Form 12257 to me by June 20, 2002.                                     
               The taxpayer’s 1998 account was credited with $300 on                  
               8/27/01.  Her $703 overpayment from her 2001 tax return                
               was credited to the 1998 year on 4/1/02.                               






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