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additional time to pay estimated tax payments for 2004 and to
complete Form 433-A by August 4, 2004.
On July 29, 2004, petitioner submitted to the Appeals
officer a completed Form 433-A and petitioner’s returns for the
taxable years 2002 and 2003. Form 433-A reported monthly income
of $1,800 and total living expenses of $1,674. The Form 433-A in
the record also contained the Appeals officer’s handwritten
notations indicating total income of $2,199 and total living
expenses of $2,024.4 The Appeals officer indicated in his notes
that Form 433-A showed that petitioner “had very little ability
to make installment payments”. Petitioner did not make estimated
tax payments by August 4, 2004, but the Appeals officer extended
the deadline for the payments until August 9, 2004.
On July 30, 2004, the Appeals officer sent petitioner a
letter acknowledging receipt of Form 433-A and petitioner’s 2002
and 2003 returns and directing petitioner to submit proof by
August 16, 2004, that petitioner’s 2004 estimated tax payments
were current.
On August 9, 2004, petitioner informed the Appeals officer
that he could pay only one-half of the 2004 estimated tax
payments with the balance payable in September 2004. On August
12, 2004, petitioner sent the Appeals officer a letter enclosing
4 The Appeals officer calculated total income by dividing
the net profit reported in petitioner’s 2003 return by 12, and he
increased living expenses by $350 for estimated tax payments.
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Last modified: May 25, 2011