Dennis and Nancy Flynn - Page 6

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          wrote petitioners to inform them that he had recommended to his             
          group manager that respondent abate the late payment addition for           
          1994.  He also told petitioners that he had denied their request            
          to abate the late payment addition for 1993 and 1995-97, in part            
          because petitioners had not had enough tax withheld for those               
          years.                                                                      
               On March 3, 1999, Leiba wrote a letter to Sims in which he             
          argued that petitioners had reasonable cause not to pay tax for             
          1993, 1995, and 1996.3  Leiba said that the taxpayers had                   
          believed that their withholding was sufficient to pay the tax due           
          for 1993 and that they had not expected to receive income of                
          $22,000 from petitioner’s ministorage partnership in 1993.                  
               Sims wrote a letter to Leiba on March 17, 1999, in which he            
          said that petitioners’ combined wages in 1993, 1995, and 1996               
          exceeded the average household income for the area.  Sims denied            
          petitioners’ request to abate the late payment addition for 1993,           
          1995, and 1996.                                                             
               2. Respondent’s Appeals Office                                         
               On April 5, 1999, Leiba wrote to Sims to tell him that                 
          petitioners would appeal to respondent’s Appeals Office Sims’s              
          denial of petitioners’ request to abate the late payment addition           
          for 1993, 1995, and 1996.  On April 20, 1999, Leiba sent to Sims            

               3  Petitioners allege that respondent abated the late                  
          payment addition for 1997.                                                  





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