Vicki S. Pless and Coy E. Pless, Jr. - Page 2

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          without conducting a hearing requested by petitioners under                 
          section 6330.  Unless otherwise indicated, all section references           
          are to the Internal Revenue Code.                                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioners resided in South Carolina at the time that their                
          petition was filed.                                                         
               Petitioners filed a joint Federal income tax return for                
          1998, reporting taxable income of $91,261, taxes of $28,113, and            
          an unpaid balance of $16,058.  The return described the                     
          occupation of petitioner Coy E. Pless, Jr. (Mr. Pless), as                  
          chiropractor and the occupation of petitioner Vicki S. Pless                
          (Ms. Pless) as office manager.  The amount shown as due was not             
          paid with the 1998 return.  As of the time of trial in October              
          2003, petitioners had not filed Federal income tax returns for              
          any years subsequent to 1998.                                               
               On September 6, 2000, the Internal Revenue Service (IRS)               
          sent to petitioners a Notice of Federal Tax Lien Filing and Your            
          Right to a Hearing Under IRC 6320 with respect to unpaid taxes              
          for 1998 in the amount of $16,616.72.  On October 2, 2000,                  
          Mr. Pless submitted a Form 12153, Request for a Collection Due              
          Process Hearing, in which he disagreed with the proposed action             
          as “Due to Business Failure”.  On October 3, 2000, Ms. Pless                






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