- 4 - 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 requestPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007