Joseph T. Hayes and Marilyn Hayes - Page 6

                                        - 6 -                                         
          suggest, any reason why respondent’s proposed levy with respect             
          to their 1994 and 1996 tax years should not proceed.5                       
               In light of the foregoing,                                             

                                             Decision will be entered                 
                                        for respondent with respect to                
                                        petitioners’ 1994 and 1996 tax                
                                        years and for petitioners with                
                                        respect to petitioners’ 1997 tax              
                                        year.                                         


















               5 At trial, respondent’s counsel suggested that as a result            
          of moving petitioners’ $611 payment from 1994 to 1997,                      
          petitioners’ 1994 balance would increase accordingly.  We note,             
          however, that respondent’s proposed levy with respect to                    
          petitioners’ 1994 taxes does not presently encompass any                    
          liabilities resulting from reversal of the $611 credit to                   
          petitioners’ 1994 account.                                                  





Page:  Previous  1  2  3  4  5  6  

Last modified: May 25, 2011