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Collection Action on 1992 Liability
Respondent contends that on December 19, 1997, petitioner’s
1992 deficiency was assessed and petitioner was sent a notice of
balance due (including accrued interest) of $14,514.53.
Petitioner disputes that any notice of balance due was ever sent.
In any event, petitioner made no payment on her 1992 deficiency
at that time.
On July 3, 2000, respondent sent petitioner a Form CP 504,
“Urgent!! We intend to levy on certain assets. Please respond
NOW.” (Form CP 504), for taxable year 1992, indicating that she
owed $23,805.53.2 By checks dated July 18, 2000, petitioner paid
respondent $14,514.53 on her 1992 account; i.e., the amount of
her balance as of December 19, 1997.3 Contemporaneously,
petitioner submitted to respondent a Form 12153, Request for a
Collection Due Process Hearing, dated July 18, 2000, with respect
to her 1992 tax year.4 On the Form 12153, petitioner complained
2 The Form CP 504 indicated that the $23,805.53 balance
included a “Penalty” of $2,622.56 and “Interest” of $4,298.30.
The $4,298.30 of “Interest” was apparently in addition to other
amounts of previously accrued interest.
3 One of the checks was for $10,195; the memo line on the
check states that it is for “Additional Tax 1992 Under Protest”.
The other check was for $4,319.53; the memo line states that this
amount is for “1992 Interest Assessment Under Protest”. A
transcript of petitioner’s account attached to the Form CP 504
sent to petitioner on July 3, 2000, showed the $4,319.53 amount
as an interest assessment that was made on Dec. 19, 1997.
4 The Appeals Office apparently treated this request as
(continued...)
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