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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 form
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Last modified: May 25, 2011