- 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 NextLast modified: March 27, 2008