David Jackson and Betty S. Jackson - Page 8

                                        - 7 -                                         
          each year in issue as of November 11, 2003, as follows:3                    
                        Unpaid                   Additions                            
             Tax Year  Balance      Interest     to Tax     Payment                   
             1995       $16.00      $2,296.04    -0-        $2,312.05                 
             1996       839.96      470.29       $147.06    1,457.31                  
             1998       14,919.06   4,402.99     2,193.00   21,515.05                 
             1999       2,986.59    629.31       437.58     4,053.48                  
             2000       27,551.08   3,163.16     2,490.54   33,204.78                 
             2001       1,931.03    153.89       301.29       2,386.21                
             Total                                          64,928.88                 
          In her cover letter, Ms. Nguyen referred to this document as an             
          “escrow demand letter”.  The cover letter also requested                    
          petitioners to sign an offer withdrawal letter concerning their             
          OIC, which petitioners signed on October 22, 2003.                          
               On or about October 16, 2003, petitioners submitted to World           
          Savings another loan application along with the escrow demand               
          letter.  World Savings approved the October 16, 2003 loan                   
          application for $64,928.88 at an interest rate of 6.25 percent              
          with a closing date of October 28, 2003.                                    
               C.  Petitioners’ Section 6330 Hearing                                  
               On October 28, 2003, petitioners attended a hearing before             
          Appeals Officer J.T. Minor (Mr. Minor).  At the hearing,                    
          petitioners requested that respondent release the lien because              
          they were refinancing their home to pay in full their tax                   
          liabilities, and that respondent abate the additions to tax and             
          the interest for the period during which respondent delayed                 


               3  Although the document appears to be a standard Internal             
          Revenue Service form, it does not indicate a form number.                   





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011