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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