- 4 -
Petitioners’ 1999 and 2000 returns reported amounts due but
included no remittances. Petitioners made no estimated tax
payments with respect to their 1999 and 2000 tax years.
Respondent assessed the amounts reported on petitioners’
returns plus statutory additions to tax as follows:
Additions to Tax
Sec. Sec. Sec.
Year Tax 6651(a)(1) 6651(a)(2) 6654
1999 $38,074 $858 $763 $814
2000 28,776 1,036 1,036 1,204
Petitioners’ Default on 1999 Installment Agreement
On December 5, 2000, petitioners entered into an installment
agreement to pay their 1999 income tax liability. Throughout
2001 they made sporadic payments totaling $3,394 before
defaulting.
Proposed Collection Action
On October 24, 2002, respondent issued petitioners a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
(the Final Notice) with respect to their income tax liabilities
for 1999 and 2000.
The Final Notice showed that petitioners owed the following
tax liabilities:
Amount due Statutory
Year on return additions Total
1999 $19,214.29 $5,077.31 $24,291.60
2000 26,947.19 2,707.37 29,654.56
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