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Court in response to the notice of deficiency. On December 16,
2002, respondent assessed the income tax deficiency, penalties,
and interest against petitioners (the unpaid tax liability).
On March 27, 2003, respondent mailed notices of intention to
levy to petitioners. In June 2003, petitioners filed an offer-
in-compromise with respect to the unpaid tax liability based on
doubt as to liability. On November 12, 2003, respondent
terminated his consideration of petitioners’ offer-in-compromise
because petitioners did not submit information that had been
requested 3 months earlier.
On May 21, 2004, respondent levied upon Mr. Guerrero’s wages
to satisfy the unpaid tax liability. That same day Mr. Guerrero
met with Mr. Quinones, an IRS collection agent. Mr. Guerrero
gave Mr. Quinones a check for $40,000 in part payment of
petitioners’ unpaid tax liability in exchange for a release of
the levy and a commitment to enter into a payment plan for the
unpaid balance. Mr. Quinones accepted the payment, released the
levy, and created a payment plan for petitioners that required
them to pay $115 per month.
On June 6, 2004, petitioners requested help from the IRS
Taxpayer Advocate’s Office with respect to the abatement of
assessed penalties and interest. On July 7, 2004, the taxpayer
advocate forwarded a Form 843, Claim for Refund and Request for
Abatement, to the IRS on petitioners’ behalf. In the Form 843
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Last modified: May 25, 2011