John F. and Carolyn J. Joseph - Page 4

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                Year    Income Tax    Statutory Additions     Total                   
                1998    $5,026.51     $2,416.16             $7,442.67                 
                1999    6,688.98      3,015.57              9,704.55                  
                2000    4,569.00      764.60                5,333.60                  
                2001    3,709.99      143.13                3,853.12                  
               On January 27, 2003, petitioners filed a Form 12153,                   
          Request for a Collection Due Process Hearing.                               
               On May 21, 2003, the IRS Appeals Office sent a letter to               
          petitioners that acknowledged receipt of their request for a                
          hearing and explained the appeal process.  On June 18, 2003, the            
          IRS Appeals Office sent petitioners a letter requesting that they           
          submit certain information, including a completed collection                
          information statement.  On July 14, 2003, the Appeals officer               
          assigned to conduct the administrative hearing sent a letter to             
          petitioners requesting that they call her to schedule the                   
          hearing.                                                                    
               Petitioners submitted a Form 433-A, Collection Information             
          Statement for Wage Earners and Self-Employed Individuals                    
          (collection statement).  On the collection statement, petitioners           
          stated that the value of their residence was $280,000, subject to           
          a $79,000 mortgage, and that they owned other real property                 
          valued at $260,000.  The value of the real property stated on the           
          collection statement was based on the assessed value of the                 
          property for property tax purposes.  On the collection statement,           








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