Marc and Sherri Ward - Page 2




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          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...)           






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