William F. Urbano and Flota L. Urbano - Page 7

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               my consent to the immediate assessment and collection                  
               of any increase in tax and penalties, and accept any                   
               decrease in tax and penalties shown above, plus                        
               additional interest as provided by law.  It is                         
               understood that this report is subject to acceptance by                
               the District Director.                                                 
               Subsequently, respondent transferred the case to the service           
          center for assessment.  Following its review of the Form 4549-CG            
          and supporting schedules, the service center concluded that the             
          revenue agent had understated the amount of interest due for 1993           
          by prematurely netting the NOL carrybacks from 1994 and 1996                
          against the adjustments for 1993.  The service center determined            
          that the deficiency and related interest for 1993 were $130,926             
          and $39,558.63, respectively.                                               
               On March 20, 2002, respondent filed the NFTL to secure the             
          payment of the disputed interest of $31,455.49 shown in his                 
          records still to be due from petitioners as of March 25, 2002,              
          with respect to their 1993 Federal income tax.3  Respondent had             
          assessed all of this interest on April 27, 1998.  Petitioners               
          requested a hearing under section 6320(b) as to this filing, and            
          Appeals later held that hearing with Bellavia.  At the hearing,             
          petitioners challenged the existence and amount of the interest             

               3 The reduction in interest from $39,558.63 to $31,455.49              
          was attributable to (1) $1,548.23 of interest that was included             
          in petitioners’ payment of $7,556.09, (2) $15.89 of overpayment             
          credits that were applied from 1995 and 1998, and (3) $6,539.02             
          of interest abated on May 4, 1998, in connection with                       
          respondent’s same-day tax abatement of $79,726 from the 1996 NOL            
          carryback.  (Respondent on Apr. 27, 1998, had abated $47,979 of             
          tax for the 1994 NOL carryback.)                                            

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