Marc and Sherri Ward - Page 3




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          The letter contained the heading "Interest & Penalty Abatement              
          Request".  The letter was accompanied by a $22,000 check and                
          requested that respondent "apply the amount to tax principal                
          only" and accept the amount as "payment in full" of petitioners'            
          outstanding "tax principal" for taxable years 1994 and 1995.  The           
          letter further requested that all interest and penalties for 1994           
          and 1995 be abated due to "financial hardships".  The letter                
          alleged that petitioners had been unaware, when they signed the             
          consent to the assessment of their tax liabilities arising from             
          the examination of their 1994 and 1995 taxable years, that the              
          amounts consented to included penalties and would continue to               
          accrue interest until paid.  The letter concluded:  "We are                 
          requesting abatement of the penalty and interest and the Service            
          accept the $22,000.00 as payment.  Please advise us of your                 
          decision."                                                                  
               Subsequent to sending the foregoing letter, petitioners                
          received a notice from respondent's Automated Collection System             
          dated December 23, 2004, that listed assessed balances, accrued             
          interest, and late payment penalties still owed with respect to             
          petitioners' 1994 and 1995 taxable years.                                   




               3(...continued)                                                        
          dates entered next to petitioners' signatures were both June 14,            
          2002.                                                                       






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