- 7 - a complete set of documents and correspondence that he had previously submitted to Sims. Leiba wanted the Appeals Office to have a complete set of documents to review in evaluating petitioners’ request. On May 25, 1999, Sims prepared a penalty appeal record regarding petitioners’ late payment addition for 1993, 1995, and 1996. In it, he pointed out that petitioners had a substantial amount of wages in 1993 and that petitioners had an inadequate amount of withholding for 1992 and 1993. On June 10, 1999, Appeals Officer Joe Gurnaby (Gurnaby) wrote Leiba to tell him that he had received petitioners’ request to abate the late payment addition for 1993, 1995, and 1996. On October 13, 1999, Gurnaby wrote Leiba to tell him that he had reviewed petitioners’ request. Gurnaby said that petitioners earned good salaries and that their withholding for 1993, 1995, and 1996 was significantly less than their tax due. Leiba faxed a letter to Gurnaby on November 24, 1999, reminding him of petitioners’ bankruptcy and foreclosure and enclosing other documents that he had provided to respondent earlier. After reviewing Leiba’s November 24, 1999, letter, Gurnaby wrote Leiba to tell him that Gurnaby would recommend that petitioners’ request to abate the late payment addition be denied. In that letter, Gurnaby stated his opinion that petitioners’ bankruptcy and foreclosure did not establish thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011