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when it was received on August 29, 2003. The return reported
adjusted gross income of $464,889, taxable income of $423,722,
total tax of $146,460, total payments of $487, and an amount owed
(again including a $1,569 Form 2210 addition) of $147,542. No
payment was submitted with the return. Amounts due, with
additions to tax and interest, were assessed on October 6, 2003,
and a notice of balance due was sent.
On September 19, 2003, Kevin A. Planegger (Mr. Planegger),
another representative of petitioners’ employed at the same firm
as Mr. Merriam, sent two letters to Mr. Skidmore. One presented
explanation and reasoning with respect to petitioners’ request
that additions to tax for 2000 be abated. The other asked that
petitioners be granted a further extension to October 3, 2003, to
provide financial and collection information. Mr. Planegger also
called on October 1, 2003, and requested still more time.
Mr. Skidmore then sent a letter dated October 16, 2003,
setting a deadline of October 27, 2003, for “full and complete
financials” from petitioners and addressing the arguments that
petitioners had proffered concerning the additions to tax. On
October 27, 2003, Mr. Planegger sent to Mr. Skidmore a completed
Form 433-A for petitioners and Form 433-B for Cox Associates,
Inc., each signed on October 24, 2003, as well as a letter
discussing certain of the income and expense items reflected
thereon. The Form 433-A showed monthly income of $14,457 and
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