- 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