- 5 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011