- 2 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011