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T.C. No. 576 (2000). It is our view that the positions
you have taken have no merit and are groundless.
An attachment to the notice of determination stated in pertinent
part:
SUMMARY AND RECOMMENDATION
* * * * * * *
Are the taxpayers entitled to relief under IRC � 6320
from the filed Notice of Lien?
No, the taxpayers did not provide any justification for
withdrawal, nor offer any collection alternatives.
BRIEF BACKGROUND
The income tax return for 1998 was filed under filing
status Married Filing Joint. The return was signed and
dated on 03/17/2000 by both taxpayers. The return
showed a balance due of $ 5,031.54 at the time of
filing. The tax was the result of insufficient with-
holding and failure to make estimated tax payments.
The income tax return for 1999 was filed under filing
status Married Filing Joint. The return was signed and
dated on 03/17/2000 by both taxpayers. The return
showed a balance due of $ 5,121.16 at the time of
filing. The tax was the result of insufficient with-
holding and failure to make estimated tax payments.
On 01/09/2002, the taxpayers called Internal Revenue to
ask for an installment agreement. The request was for
the years 12/1996, 12/1997, 12/1998, 12/1999 and
12/2000.
IRS responded on 01/18/2002 by establishing an agree-
ment for $ 400 per month.
The taxpayers defaulted on their agreement and on
06/24/2002; the Internal Revenue gave formal notice of
intent to terminate the agreement.
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