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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.
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