Davis and Lois Etkin - Page 6

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         years.  Petitioners made payments from November 2000 until                   
         September 2003.  On December 6, 2000, the revenue agent rejected             
         petitioners’ proposed January 2000 installment agreement and                 
         referred the case to the Appeals Office to fulfill petitioners’              
         request for a hearing.  In their Form 12153, petitioners again               
         requested an installment agreement and claimed that the monthly              
         payments previously determined by the revenue agent exceeded                 
         their ability to pay.                                                        
              The Appeals officer engaged in a series of phone calls and              
         letters with petitioners’ representative concluding sometime in              
         November 2001.  On July 12, 2001, the Appeals officer mailed to              
         petitioners a letter offering them the opportunity to have a                 
         face-to-face conference on July 25, 2001, for the taxable years              
         1997-99.  At petitioners’ representative’s request, the Appeals              
         officer rescheduled the conference for September 12, 2001, at the            
         Appeals Office.  Neither petitioners nor their representative                
         appeared for the September 12, 2001, conference.  On November 9,             
         2001, respondent mailed to petitioners a followup letter giving              
         them 2 weeks to raise any additional issues regarding the lien or            
         intent to levy.  Petitioners’ representative then contacted the              
         Appeals officer and, on behalf of petitioners, proposed an                   
         installment agreement requiring monthly payments of $800 over 5              
         years to pay their outstanding tax liability of $55,362.13, which            
         terms were the same terms the revenue agent in charge of                     






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