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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.
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Last modified: May 25, 2011