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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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Last modified: May 25, 2011