- 3 -
The letter detailed petitioners’ equity and future ability to pay
totaling $427,532. Petitioners offered $3,000 to pay a balance
due at that time of $7,961. The letter further noted that
petitioners’ special circumstances were considered, but they did
not warrant a decision to accept the offer.
Meanwhile, respondent issued to petitioners a notice of
intent to levy dated July 12, 2002, for the 1997 taxable year.
Petitioners submitted a timely Form 12153, Request for a
Collection Due Process Hearing. Petitioners attached a statement
explaining their position. Petitioners asserted that they were
out of work and that Mrs. Conner was disabled. Petitioners
asserted that they were in very poor financial condition. They
further asserted that the IRS had delayed resolution of their
case and asked that interest and “penalties”2 be abated.
Petitioners paid the balance due on May 14, 2003, after the
notice of demand for payment but prior to the issuance of the
notice of determination. Petitioners however seek an abatement
of interest and additions to tax.
On June 9, 2003, the Appeals Office issued the notice of
determination that petitioners are not entitled to an abatement
of interest or additions to tax. A timely petition was filed.
2The parties have each referred to “penalties”; however we
understand the parties’ reference to mean the additions to tax
under sec. 6651(a)(1) and (2).
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011