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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 --
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Last modified: May 25, 2011