Hailu Yohannes Awlachew - Page 8




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          the poor economy, his lack of knowledge of the tax law, and his             
          fear of losing his job.  Petitioner requested guidance on                   
          obtaining an abatement of interest and relief from the additions            
          to tax.  By letter dated August 9, 2005, the settlement officer             
          detailed the requirements for a request for relief from additions           
          to tax,7 informed petitioner that respondent was required by                
          statute to assess interest in his case and that the interest                
          could not be abated, and referred petitioner to the Internal                
          Revenue Manual for further information.  By letter dated August             
          29, 2005, petitioner once again requested the abatement of                  
          interest and relief from the additions to tax because of the                
          downturn in the economy and his lack of knowledge regarding the             
          tax implications of employee stock options.                                 
               On November 18, 2005, respondent issued to petitioner a                
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 (notice of determination).  The notice             
          of determination stated that respondent had verified that all               
          statutory and administrative requirements had been met, that                
          respondent had addressed all of petitioner’s arguments raised at            
          the face-to-face hearing, and that respondent had determined that           
          the lien appropriately balanced the Government’s need for the               
          efficient collection of taxes and petitioner’s concern that the             


               7The settlement officer used the term “penalties” in the               
          letter, but she was referring to additions to tax.                          






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