Omar Urbina Pineda - Page 8

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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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