Don Evan and Vicky Kay Whitinger - Page 8

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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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