Nicholas & Carrie Cozzens - Page 6

                                        - 6 -                                         
               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.                                     








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011