- 2 -
Court. Petitioners filed a response, and the Court conducted a
hearing on the matter.
Background
At the time their petition was filed, petitioners resided in
Pennsylvania.
Petitioners did not timely file returns for their 1994 or
1995 taxable year. On June 29, 1999, subsequent to an
examination by respondent, petitioners signed a Form 870-AD,
Offer to Waive Restrictions on Assessment and Collection of Tax
Deficiency and to Accept Overassessment, agreeing to the
assessment and collection of deficiencies and section 6651(a)(1)
additions to tax for 1994 and 1995 "with interest as provided by
law".2 Respondent accepted petitioners' offer by countersigning
it on August 10, 1999.
Petitioners received a notice of intent to levy concerning
their tax liabilities for 1994 and 1995 on or about July 27,
2001. Petitioners did not request a hearing after receiving this
notice.
On or about June 14, 2002, petitioners mailed a letter,
prepared by their attorney and signed by them,3 to respondent.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986 as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
3 The letter, dated June 12, 2002, was signed by
petitioners' attorney and petitioners. However, the handwritten
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: March 27, 2008