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installment arrangement they would (1) make monthly payments of
$400, (2) timely file all tax returns, and (3) timely pay all
Federal taxes that become due. Petitioners paid $400 monthly
from January through July 2001. They did not make an installment
payment in August 2001.
After petitioners failed to make the August 2001 payment,
the installment agreement was revised to include unpaid taxes for
2000, and the amount of the monthly payments was increased to
$700. Petitioners paid $676 in September 2001 and made monthly
payments of $700 from October 2001 through July 2002 and in
October 2002.3 They did not make a payment in August or September
2002 or after October 31, 2002.
On January 4, 2003, the Internal Revenue Service (IRS)
mailed to petitioners a Final Notice of Intent to Levy and Notice
of Your Right to a Hearing (the levy notice) with respect to
petitioners’ liability for income taxes for 1998-2001. The levy
notice reflects the following unpaid tax liabilities for 1998-
2001:
3Petitioners made two payments of $700 each in January 2002
but did not make a payment in February 2002.
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Last modified: May 25, 2011