Estate of Nancy Sblendorio, Deceased, Michael F. Poppo, Executor - Page 4
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telephone conversations with the Appeals officer, Mr. Poppo again
requested relief from the additions to tax for reasonable cause.
On April 5, 2004, while the appeal was still pending, the
Cincinnati Service Center issued a notice to Mr. Poppo indicating
that the additions to tax had been reduced. This notice was
without explanation, and in response, Mr. Poppo sent a letter to
the Cincinnati Service Center asking for more information. On
June 9, 2004, the Cincinnati Service Center issued a letter
explaining that the additions to tax for late filing had been
reduced to account for the extension of time to file the return.
On August 31, 2004, respondent’s Appeals Office issued a
letter to Mr. Poppo indicating that the assessed additions to tax
had been sustained. The Appeals officer stated that Mr. Poppo
had not established reasonable cause for the late filing and
failure to pay. The Appeals officer further indicated that Mr.
Poppo failed to provide information to support his belief that
the return had been filed and taxes paid timely and that Mr.
Poppo failed to provide a copy of the approved extension of time
to file as requested by the Appeals officer.
On November 19, 2004, respondent issued to the estate a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under I.R.C. 6320. Thereafter, Mr. Poppo timely submitted Form
12153, Request for a Collection Due Process Hearing, on behalf of
the estate. The only issues Mr. Poppo raised in this request
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Last modified: November 10, 2007