Hugh D. Summers and Teresa E. Summers - Page 9

                                        - 9 -                                         
          that respondent did not properly credit the payments from                   
          Commonwealth to her account.                                                
               On December 17, 2003, the District Court entered judgment in           
          favor of respondent and against Mrs. Summers, ordering Mrs.                 
          Summers to pay $735,902.85 for unpaid Federal income taxes for              
          1985, 1986, 1988, and 1989, plus interest accruing thereon at the           
          rate provided by section 6621 from September 30, 2003, until paid           
          and a $13,858 negligence penalty assessed on November 24, 1997.             
               Petitioners’ Appeal to the Third Circuit Court of Appeals              
               Petitioners appealed the respective judgments against them             
          to the United States Court of Appeals for the Third Circuit                 
          (Court of Appeals for the Third Circuit).  Petitioners’ appeals             
          were consolidated at United States v. Teresa E. Summers, No. 04-            
          1375, and United States v. Summers, No. 04-1379.  On January 4,             
          2005, the Third Circuit Court of Appeals affirmed the District              
          Court judgments against petitioners.                                        
               Petitioners’ Section 6330 Action Relating to Taxable Year              
          1989                                                                        
               Petitioners failed to pay their income tax liability for               
          1989.  On April 15, 2002, respondent sent petitioners’ attorney,            
          who was authorized to receive such notices, a Final Notice of               
          Intent to Levy and Notice of Your Right to a Hearing.  On May 10,           
          2002, petitioners, through their attorney, submitted a Form                 
          12153, Request for a Collection Due Process Hearing.  Attached to           







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011