Gary and Cynthia Stein - Page 7

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          Collection Actions                                                          
               Although petitioners paid $27,000 when respondent accepted             
          the OIC, petitioners did not make any further payment under the             
          terms of the OIC; namely the $5,000 payment due on September 27,            
          1997.  The record indicates that the $27,000 paid was applied to            
          amount of the OIC total attributable to taxable year 1993.  This            
          application resulted in the settlement of the 1993 taxable year.            
          However, because petitioners did not remit the remainder of the             
          OIC amount, a liability for taxable year 1994 remained.                     
               On October 6, 1997, respondent sent petitioners a letter               
          that applied interest on the unpaid portion of their income tax             
          liability stemming from taxable year 1994.  On May 4, 1998,                 
          respondent assessed a deficiency of $12,525.27 for taxable year             
          1994.                                                                       
               As previously discussed, petitioners did not timely file,              
          timely pay, and/or fully report their income for taxable years              
          1997, 1998, 1999, 2000, and 2001.  Although respondent’s                    
          Collections personnel were in contact with petitioners regarding            
          their outstanding liabilities for these years, the personnel did            
          not revisit the unpaid portion of the 1994 assessment until early           
          2001.                                                                       
               On May 1, 2001, and August 31, 2002, respectively,                     
          respondent sent petitioners letters warning them that if they did           
          not become compliant with the unpaid liability for taxable year             






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