Louis A. and Christine Cox - Page 6

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               Meanwhile, on July 24, 2003, petitioners filed a Form 1040             
          for 2001.  The return reported adjusted gross income of $190,054,           
          taxable income of $104,746, total tax of $38,175, total payments            
          of $6,000, and an amount owed (after a $1,511 Form 2210 addition)           
          of $33,686.  No payment was made with the return.  Amounts due,             
          with further additions to tax and interest, were assessed on                
          September 8, 2003, at which time a notice of balance due was                
          sent.                                                                       
               The scheduled telephone conference for 1999 and 2000 was               
          conducted on August 12, 2003.  The participants discussed the               
          changing nature of petitioners’ business and their financial                
          circumstances.  To wit, Mr. Cox’s consulting endeavors had                  
          previously focused on the telecommunications industry, where work           
          had since “dried up” due to the economic downturn.  He was at               
          that time soliciting a more diversified clientele, but contracts            
          were smaller and income reduced.   It was agreed that petitioners           
          would provide Forms 433 by the end of August for the                        
          consideration of collection alternatives, and options discussed             
          included an offer-in-compromise or currently not collectible                
          status.                                                                     
               On August 28, 2003, Mr. Merriam telephoned Mr. Skidmore to             
          request 3 more weeks to submit financial information and to                 
          communicate that petitioners’ 2002 Form 1040 had been mailed.               
          The return for 2002 was timely filed, pursuant to extensions,               






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