- 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 toPage: 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