Louis A. and Christine Cox - Page 11

                                       - 11 -                                         
               Your lack of current tax compliance defeated the                       
               finding of collection alternatives, and the financial                  
               information you provided indicated an ability to make                  
               significant payments on the outstanding tax, if not                    
               fully pay it over the next few years.  You did not                     
               evidence that a levy would be overly intrusive.  You                   
               did not show reasonable cause for penalty abatement.                   
          Petitioners filed a petition with this Court challenging the                
          November 25, 2003, determination on December 22, 2003, at which             
          time they resided in Denver, Colorado.                                      
               In the meantime, on October 20, 2003, the IRS had issued to            
          petitioners a Final Notice - Notice of Intent To Levy and Notice            
          of Your Right to a Hearing with respect to 2001 and 2002.                   
          Petitioners timely submitted a Form 12153, received by the IRS on           
          November 19, 2003, in response to the notice of intent to levy.             
          An attachment explaining their disagreement essentially reprised            
          (almost verbatim) the points made in their November 17, 2003,               
          letter to Mr. Skidmore and focused on a request for placement of            
          their accounts in currently not collectible status.                         
               This case was again assigned to Mr. Skidmore.  By a letter             
          dated April 8, 2004, Mr. Skidmore offered a hearing to be held on           
          April 27, 2004.  On April 20, 2004, petitioners’ representative             
          called and requested that Mr. Skidmore recuse himself and have a            
          different Appeals officer handle the 2001 and 2002 case on                  
          account of Mr. Skidmore’s work on prior years.  Upon review of              


               3(...continued)                                                        
          second copy.                                                                





Page:  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