- 6 - Taxable Period Tax Penalty Interest 1993 $122,463 $91,847 $157,408 1994 3,695 2,771 4,221 1995 17,312 12,984 15,085 1997 42,049 4,245 7,453 1998 38,264 2,167 4,060 On June 1, 2000, respondent issued Forms 668-A(c)(DO), Notice of Levy, to Travis Morgan Securities, Inc., with respect to certain nominee stock accounts held on petitioners’ behalf. Respondent’s collection division took the position that these stock accounts had a value of approximately $1 million--more than enough to pay off fully petitioners’ then-outstanding tax liabilities of about $500,000. By letter dated June 21, 2000, petitioners requested a section 6330 Appeals hearing with respect to the jeopardy levy. In November 2000, Appeals Officer Janice Rich was assigned to consider petitioners’ request for an Appeals hearing. In the initial stages of the proceedings in the Appeals Office, petitioners were represented by Mr. Spirtos; however, on April 30, 2001, respondent received a Form 2848, Power of Attorney and Declaration of Representative, for Steven R. Mather (Mr. Mather). From that point on, Mr. Mather represented petitioners in the Appeals Office. In their Appeals Office case, petitioners raised the following issues: (1) That they were not liable for the amounts of tax asserted in the Form 4549-CG because they signed that formPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011