Omar Urbina Pineda - Page 9

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          a check of $1,075 for one-half of petitioner’s 2004 estimated tax           
          payments.  The letter further indicated that petitioner would pay           
          the balance in full on or before September 16, 2004.                        
               On September 29, 2004, petitioner sent the Appeals officer a           
          letter stating, inter alia, that he would be mailing the balance            
          due for his 2004 estimated tax payment on October 4, 2004.                  
               On October 4, 2004, petitioner sent the Appeals officer a              
          letter enclosing a check of $1,074 for the remaining balance of             
          petitioner’s 2004 estimated tax payments.                                   
               By October 15, 2004, petitioner was in compliance with his             
          tax obligations sufficient for consideration of a collection                
          alternative such as an installment agreement.  The Appeals                  
          officer determined, however, that there was an income discrepancy           
          of $175 between Form 433-A and petitioner’s 2003 return.  The               
          Appeals officer requested petitioner to submit additional                   
          financial information by November 4, 2004.  On November 5, 2004,            
          petitioner requested additional time.  At a time not disclosed in           
          the record, petitioner submitted bank and expense statements,               
          business and rent invoices, and utility invoices.  On November              
          16, 2004, the Appeals officer closed petitioner’s case because              
          petitioner failed to provide the requested information by the               
          deadline.                                                                   









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