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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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Last modified: May 25, 2011