David Jackson and Betty S. Jackson - Page 10

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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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