- 7 - On April 29, 2004, respondent sent to petitioners a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for the 1999 taxable year. In the notice, respondent determined that all applicable laws and administrative procedures had been satisfied and that petitioners had proposed an offer-in-compromise but failed to provide any financial information or documentation and to pay the filing fee. Respondent also determined that petitioners had paid the $363 deficiency for 1999, but that the original tax due of $13,389 as reported on their 1999 return remained unpaid. Concluding that the proposed levy represented an appropriate balancing of the need for efficient collection with the concern that the collection action be no more intrusive than necessary, respondent determined that the proposed levy could proceed. On May 24, 2004, petitioners submitted a timely petition to this Court for review of the determination. Discussion A. Petitioners’ Contentions In their petition, petitioners contend that respondent’s representatives were “dishonest” and that petitioners would suffer economic hardship if they were required to pay the amount due as reported on their 1999 return. Petitioners argue that their payment of the amount due in the notice of deficiency for 1999 was a full settlement of their 1999 tax liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011