- 5 - You still owe the balance due and penalty and interest will continue to accrue until the balance due has been paid in full, but we are not enforcing collection until you are able to make payments on the balance due at some point in the future.” Thereafter, the case was assigned to the IRS Office of Appeals in Phoenix, Arizona. Settlement Officer Thomas L. Tracy (Mr. Tracy) sent petitioner and Ms. Picchiottino a letter dated November 5, 2003, scheduling a hearing for November 25, 2003, and briefly outlining the hearing process. Petitioner and Ms. Picchiottino then submitted another Form 12153 with respect to all 4 years dated November 7, 2003, and received by the IRS on November 13, 2003. They checked the box indicating disagreement with a filed notice of Federal tax lien and wrote: “Request without predjudice [sic] that hearing be held after Superior Court Action FN 2003-092649 is adjudicated.” Mr. Tracy responded by a letter to petitioner dated November 13, 2003, stating: I am in receipt of Form 12153 signed by you and Kathryn Picchiottino on November 7, 2003. It states only that you wish a hearing after Superior Court Action FN 2003- 092649 is adjudicated. I understand that this is your divorce suit. I am sorry, but I cannot defer action on your case for an extended and indefinite period of time. We mutually scheduled the November 25 hearing and if that date is inconvenient, I will gladly reschedule to accommodate you. If we cannot schedule and hold a hearing by December 10, 2003, I will make my determination from information in the file and with no further hearing opportunity.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011