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On June 23, 2000, respondent sent petitioners, by certified
mail, a Letter 1058, Notice of Intent to Levy and Notice of Your
Right to a Hearing, for 1998 (June 23, 2000, notice). The return
receipt for the June 23, 2000, notice was signed on June 26,
2000.
On November 20, 2000, respondent assessed tax liabilities of
$38,661 plus additions to tax for 1999. Respondent issued two
notices of demand for payment of the 1999 tax liabilities and
additions to tax on November 20 and December 11, 2000.
On January 5, 2001, petitioners entered into an installment
agreement for the payment of the 1998 and 1999 tax liabilities.
Petitioners did not make all of the monthly payments as required
by the installment agreement schedule. By December 2001, the
installment agreement was terminated.
On December 14, 2001, respondent sent petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing for 1998 and 1999 (December 14, 2001, notice). The taxes
owed with statutory additions, as set forth in the final notice,
were $41,435 and $44,345 for 1998 and 1999, respectively.
Mr. Orum sent respondent a Form 12153, Request for a
Collection Due Process Hearing (hearing request), for 1998 and
1999, dated December 31, 2001. On the hearing request,
petitioners stated: “Desires continuation of payment plan. Will
contact IRS agent by phone to discuss. Have been working with
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Last modified: May 25, 2011