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pay their delinquent income tax liabilities.
With respect to petitioners’ request to abate the additions to
tax, respondent sustained the abatement of $596.02 of the
addition to tax for late payment because “there was some delay in
providing the taxpayer’s timely information regarding the amounts
due on their delinquent income tax liabilities”.
E. Petition
On January 12, 2004, petitioners filed with the Court a
petition under section 6330(d) disputing respondent’s
determinations. See sec. 6320(c). Paragraph 4 of the petition
states:
I request that I be relieved from all interest and
penalties in connection with the tax years described in
paragraph 2. The CDP Determination Letter attached
indicated that there was delay in providing the
taxpayer timely information and therefore abated a
portion of the failure to pay penalties for reasonable
cause. The $596.02 did not address the IRS action
regarding the lien and other damages and costs incurred
as a result of their actions. I have since acquired a
loan and paid the taxes of $64,928.88 in full. This
amount includes $11,115.68 interest and $5,596.47 in
penalties. I respectfully request a return of the
interest and penalties less the $596.02 for a total of
$16,116.13 for cause and hardship.
F. Release of the Lien
On January 30, 2004, respondent released the Federal tax
lien because petitioners paid in full their tax liabilities
including interest and additions to tax for the years in issue.4
4 The record does not explain why it took respondent 3
(continued...)
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