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6/26/97 100 1990
7/25/97 100 1990
8/25/97 100 1990
9/25/97 100 1990
10/23/97 100 1990
11/20/97 100 1990
12/22/97 100 1990
On or about December 4, 1996, petitioners submitted an offer-in-
compromise with respect to petitioners’ 1990 liability.
Respondent rejected the offer-in-compromise on February 22, 1997.
From January of 1998 until March of 2003, respondent applied
petitioners’ monthly $100 payments exclusively to petitioners’
1990 liability.2 Petitioners failed to file tax returns with
respect to their 1999, 2000, 2001, 2002, and 2003 tax years,3 and
respondent terminated the installment agreement in 2003.
On September 10, 2004, respondent issued to petitioners a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing with respect to petitioners’ 1994 tax year. The notice
asserted an unpaid tax in the amount of $1,603.56, accrued
interest in the amount of $2,217.08 and a “late payment penalty”
in the amount of $624.82. Petitioners timely requested an
administrative hearing before respondent’s Appeals Office
pursuant to section 6330 (section 6330 hearing).
2From January of 1998 until March of 2003, respondent
applied 63 separate $100 payments to petitioners’ 1990 liability
and zero payments to petitioners’ 1994 liability.
3As of the date of the trial, petitioners had still not
filed tax returns with respect to their 1999, 2000, 2001, 2002,
and 2003 tax years.
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Last modified: May 25, 2011