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net deficiency after taking into account the May 27, 1996,
assessment. The parties subsequently agreed to the $2,931
deficiency, and, on March 13, 1997, the Court entered a decision
pursuant to the parties’ stipulated agreement as follows:
ORDERED AND DECIDED: That there is a deficiency
in income tax due from the petitioners for the taxable
year 1993 in the amount of $2,931.00; and
That there is no addition to tax due from the
petitioners for the taxable year 1993, under the
provisions of I.R.C. � 6662(a).
On May 19, 1997, respondent assessed the $2,931 deficiency
and sent petitioners a notice and demand for $21,164. On June
25, 1999, petitioners filed a third amended return relating to
1993.
On September 20, 2000, respondent sent petitioners a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing relating to 1993. On October 17, 2000, petitioners filed
Form 12153, Request for Collection Due Process Hearing (hearing
request). Section 6330 hearings were held on March 13 and May 1,
2001. On May 15, 2001, petitioners amended their original
hearing request.
On June 28, 2001, respondent sent petitioners a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. On July 31, 2001, petitioners, while residing in
Glendale, Arizona, filed their petition with the Court. On
August 7, 2001, petitioners filed an amended petition.
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Last modified: May 25, 2011