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will be assessed as provided by law on the deficiency”. The
decision was entered by the Court on February 25, 2002, and the
assessment was made on July 22, 2002.
Administrative Activity
Notice and demand was issued for the deficiency assessment
followed by several additional notices of tax due. Receiving no
response or payment, respondent sent to petitioners Letter 1058,
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing.
Petitioners filed a timely Form 12153, Request for a
Collection Due Process Hearing. Attached to the Form 12153 was a
statement that petitioners had not agreed to pay any interest
because “there was still a question whether the Internal Revenue
Service was entitled to” the deficiency. According to the
statement, petitioners agreed to pay “$26,927.67”,1 in essence,
only because an Internal Revenue Agent told them that they “could
work out an affordable payment schedule.” The statement cites as
petitioners’ objective in the section 6330 hearing the
presentation to Appeals of “documentation with the view to
discharge of the original assessed balance.”
The Appeals officer who conducted the hearing informed
petitioners that because the underlying tax liability had been
1The actual amount to which the parties agreed was
$26,955.75.
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Last modified: May 25, 2011