- 3 - Petitioner wife wrote the following on the signature page of the Form 4549-CG: Upon receipt of this letter, I spoke with Mrs. Dillard on January 31, 199[ ] [illegible]. She explained and was very helpful in pointing out the additional taxes. We do not dispute the amount and are presently in an installment agreement with the IRS and will continue to make monthly payments to pay off the amount in full. Thank you. Respondent computes that petitioners have a remaining, unpaid income tax liability for 1995 of $2,995.07 (the remaining liability).2 On December 20, 2001, respondent issued to petitioners a notice of intent to levy and of petitioners’ right to a hearing under section 6330. Petitioners requested a hearing under section 6330, and, pursuant to the request, petitioner wife met with Appeals Officer Murphy on January 6 and 14, 2003 (the section 6330 hearing). At the section 6330 hearing, petitioners did not 2 That amount is respondent’s computation of the remaining liability as of approximately the time of trial. Respondent computes that amount as follows: 1995 Return Liability Payment Return as filed $ 4,901.00 -- Withholding -- $2,422.17 Estimated tax penalty 120.63 -- Failure to pay penalty 12.39 -- Interest 15.22 -- Form 4549-CG 5,282.00 -- Payments -- 4,914.00 $10,331.24 $7,336.17 Remaining liability $ 2,995.07 --Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011