- 5 -
pay $9,918.4 His reasons, as stated in the OIC, for thinking
that he should be entitled to relief from interest and penalties
included, inter alia:
By agreeing to enter a plea * * * I spared the government
the time and expense of indicting me.
By entering into a plea agreement, I spared the government
the time and expense of trying me.
* * * * * * *
By completing my probationary period without serious
incident, I spared the government the time and expense of
re-sentencing and incarcerating me.
Petitioner also disputed his ability to pay, and he argued
that it would “create an economic hardship and * * * be unfair
and inequitable” to require him to pay the interest and penalty
portions of his potential liability. Not surprisingly,
petitioner’s OIC was rejected.
In response to petitioner’s disagreement with the civil
fraud penalties, respondent mailed petitioner a second Form 4549.
This one showed an amount due of only $9,918 and specifically
excluded civil fraud penalties. The Form 4549 noted that
interest would be calculated at the time of assessment.
Petitioner signed the Form 4549 and a Form 870, Waiver of
Restrictions on Assessment and Collection of Deficiency in Tax
4 This amount represented the sum of the underpayments of
tax for the taxable years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: November 10, 2007