Nield and Linda Montgomery - Page 11

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          alternative minimum taxable income (AMTI), and AMT of $526,679.             
          Petitioners’ tax return was prepared and signed by a tax return             
          preparer employed at Deloitte & Touche LLP.                                 
               Petitioners failed to remit the full amount of tax due with            
          their tax return.  Respondent accepted petitioners’ tax return as           
          filed and assessed the tax reported therein, as well as statutory           
          interest and a late-payment penalty.                                        
               Respondent issued to petitioners a Final Notice of Intent to           
          Levy and Notice of Your Right to a Hearing with regard to their             
          unpaid taxes for 2000.  Petitioners submitted to respondent an              
          amended return for 2000 and a request for an administrative                 
          hearing under section 6330.  In their amended return, petitioners           
          claimed that they overstated the amount of tax due on their                 
          original return, and they claimed they were due a refund of                 
          $519,087.  Contrary to their original return, petitioners                   
          submitted a Form 6251 with their amended return in which they               
          reported $850,534 of alternative minimum taxable income in excess           
          of regular taxable income, a total of $7,148,666 of AMTI, and               
          zero AMT.                                                                   
               Respondent declined to consider petitioners’ refund claim              
          and issued to petitioners a Notice of Determination Concerning              
          Collections Actions for 2000.  Petitioners filed a petition for             
          lien or levy action with the Court at docket No. 16864-02L.  Upon           
          review of the matter, the Court remanded the collection case to             






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