John P. and Sharon Lynn - Page 5

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               Respondent’s Appeals Office assigned the case to Settlement            
          Officer A.T. Munson, who had no prior involvement with                      
          petitioners’ 1994 tax liability.  On February 3, 2005, Settlement           
          Officer Munson conducted a face-to-face conference with                     
          petitioner.  During the conference, petitioner contended that               
          respondent did not properly apply payments made under the                   
          installment agreement to petitioners’ 1994 liability and that               
          respondent improperly terminated the installment agreement.                 
          Additionally, petitioner stated that petitioners intended to                
          contest in court the penalties and interest related to their 1994           
          liability.  Settlement Officer Munson informed petitioner that              
          respondent applied the disputed payments to petitioners’ 1990               
          liability rather than petitioners’ 1994 liability and that                  
          respondent terminated the installment agreement because                     
          petitioner did not file tax returns or pay taxes owed with                  
          respect to petitioners’ 1999, 2000, 2001, 2002, and 2003 tax                
          years.                                                                      
               On February 25, 2005, respondent’s Appeals Office issued a             
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330, sustaining the proposed levy.                     
          Petitioners timely petitioned the Court.  The petition set forth            
          the following reasons for relief:  “IRS not fullfilling [sic]               
          original agreement.  Subsequently causing significant additional            
          penalty and interest to accumulate.  Much anguish and                       






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