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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
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