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