- 6 -
3. See copy of your letter attached.[6]
4. Tax years involved are 1999, 2000, 2001,
2002 and 2003.
5. I do not agree with your conclusion that we
owe any money to you. We did not owe when
we filed our 1999 return. You owe us a
refund for 2000, 2001, 2002, and 2003. Not
to mention the $600.00 refund that we never
received. Amount owed us is approximately
$20,000.00!!!!! Plus interest for four
(4) years * * * [Reproduced literally.]
On or about September 15, 2004, an Appeals officer with
respondent’s Appeals Office (Appeals officer) sent petitioner a
letter. That letter stated in pertinent part:
In review of your protest and/or request for a hearing,
I find that the outstanding liabilities are from your
own late filing of the 1999 return. The first liabil-
ity was established by the Service with some limited
information after you defaulted your right to petition
the Tax Court. Thereafter, you submitted a return for
1999 with a higher liability.
Since the due date of the return was April 15, 2000,
you were assessed the failure to file penalty, the
failure to pay penalty and interest. As the Service
took funds from other returns, adjustments were made to
the penalties and interest since some of the payments
from other returns were not known until after the
penalties and interest were assessed, but the effective
date of the refunds took effect earlier.
* * * The total assessed balance is currently
$18,309.15 since the Service took $2,236.51 levy funds
on May 17, 2004.
* * * * * * *
6Petitioner attached to his March 8, 2004 letter Form CP
504, “Urgent!! We intend to levy on certain assets. Please
respond NOW.” (Form CP 504). The Internal Revenue Service (IRS)
had issued Form CP 504 to him with respect to petitioner’s unpaid
total 1999 liability.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011