- 3 - amount of the excess credit that had been claimed3 as well as the tax shown as due and owing on the return Sec. 6213(b). On July 30, 2002, respondent notified petitioners of an intent to levy with respect to petitioners’ unpaid tax liabilities for 1998 and 1999. The notice listed $2,729.10 due for 1998 and $3,014.71 due for 1999. Petitioners filed a timely Form 12153, Request for a Collection Due Process Hearing. In their request, petitioners requested an explanation of their underlying tax deficiencies for the years in question and complained of numerous delays by the IRS. An Appeals officer subsequently provided petitioners with a written explanation of both their error and the IRS adjustments. Petitioners did not offer any documentation in dispute of this explanation, nor did they propose any collection alternatives; therefore, on August 15, 2003, respondent issued a Notice of Determination to petitioners, concluding: you have not established the underlying tax liability to be incorrect. You did not correctly figure the limitation on low-income housing credits on your original tax returns, and they were corrected during processing. You did not provide financial information, as requested, to enable consideration of collection alternatives * * * The tax will not be abated and the lien will not be released or withdrawn. 3The record does not reflect the exact dates on which the errors on petitioners’ 1998 and 1999 Federal income tax returns were corrected; however, petitioners stipulated the underlying tax deficiencies for both years. The exact dates, therefore, are inconsequential.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011