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• You had not made any estimated tax payments for 2001
and 2002
Keith provided an adequate explanation why a Form 1065
for 1998 was not filed. The only other partner resigned
prior to 1998. The partnership dissolved, but Keith
continued to use the partnership federal employer’s
identification number (FEIN) for reporting employment tax
returns. * * * Keith said he understood why an offer could
not be considered and expressed an interest in an
installment agreement.
* * * * * * *
A scheduled telephone conference was held on July 23,
2002 at 10:10 a.m. EST with Keith Orum. The Settlement
Officer reviewed the information on Form 433A with him and
identified additional information needed in order to
determine an appropriate amount for an installment
agreement. The additional financial information was to be
provided by August 9, 2002.
* * * * * * *
We received an estimated tax payment for 2002 in the
amount of $8,500 on September 6, 2002 however; we have not
received the additional financial information nor heard from
you.
BALANCING EFFICIENT COLLECTION AND INTRUSIVENESS
You have failed to provide by an agreed deadline the
additional financial information requested. This
information is necessary in order for us to consider an
installment agreement. Absent your willingness to provide
this information, alternatives to the proposed levy action
such as an installment agreement could not be considered.
* * *
On November 15, 2002, petitioners sent the Court a Petition
for Lien or Levy Action Under Code Section 6320(c) or 6330(d) to
dispute the decision letter for 1998 and the notice of
determination for 1999. On January 21, 2003, petitioners sent
the Court an amended petition pursuant to a Court order.
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Last modified: May 25, 2011