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Appeals received and reviewed all TC 300 assessments
documents in addition to the Tax Court Decision documents for tax
years 1988-1992, inclusive. All TAX as stipulated by the Tax
Court was correctly assessed for the years in question. However,
Appeals did conclude that Mr. Reese was not given proper credit
for his federal income tax withholding for the years 1989, 1990
or 1992.
Appeals prepared three adjustment documents (Form 3870)
to give Mr. Reese the following credit: $2,840 for
1989, $3,517 for 1990 and $295 for 1992. (No
adjustments were warranted on tax years 1988 or 1991 as
the correct amount of tax was assessed with the correct
amount of withholding credits given per year). Mr.
Reese was advised of the Appeals adjustments.
Mr. Reese was requested to provide a repayment proposal
(such as an Installment Agreement or an Offer in
Compromise) to Appeals by October 1, 2004 in lieu of
the proposed collection actions as the minimal
adjustments requested by Appeals would NOT satisfy his
tax indebtedness to the IRS. There was no further
response nor information received from Mr. Reese.
Accordingly, there was no agreement reached on this
account.
The taxpayer raised no other issues. [Emphasis added.]
Petitioner filed his petition on T.C. Form 2 (Rev. 5/03).
Petitioner’s request for relief and statement of error, as stated
in the petition, is as follows:
4. Set forth the relief requested and the reasons
why you believe you are entitled to such relief. 1.)
Abatement of all excessive and wrongful IRS
assessments. 2.) Proper accounting of my liability.
The fact situation underlying this case is the
egregious pattern and practice by the IRS of issuing
excessive and wrongful assessments and ignoring
requests to abate those wrongful assessments. The IRS
Appeals Officer acted in bad faith by imposing an
illusory conclusion to this problem that failed to
mitigate harm caused by IRS misfeasance and excessive
interest caused by IRS delays. The Appeals Officer
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Last modified: May 25, 2011