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