- 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
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