- 9 - 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...)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