- 6 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011