David and Monika Zisskind - Page 5




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          2004, Mr. Burke sent a letter to Ms. Russo disputing petitioners’           
          liability for the additions to tax under section 6651(a)(1) and             
          (2).                                                                        
               Petitioners’ section 6330 hearing was held on December 16,             
          2004.  During the hearing, petitioners contested their liability            
          for the additions to tax under section 6651(a)(1) and (2),                  
          requested an abatement of interest under section 6404(e), and               
          requested the withdrawal of the Federal tax lien.  Ms. Russo                
          informed petitioners they would not be liable for the additions             
          to tax under section 6651(a)(1) and (2) if they could establish             
          that their failure to timely file and pay was due to reasonable             
          cause.  Ms. Russo requested that petitioners provide her with               
          additional information to establish reasonable cause.                       
               Between January 31 and April 22, 2005, petitioners provided            
          Ms. Russo with bank statements, their 2000 Federal income tax               
          return, and other information intended to establish reasonable              
          cause for their failure to timely file and pay.  On April 27,               
          2005, Ms. Russo advised petitioners that she would review the               
          information submitted and make her determination.                           
               On July 1, 2005, respondent issued petitioners the notice of           
          determination.  Respondent determined that petitioners                      
          established their failure to timely file was due to reasonable              
          cause.  Accordingly, respondent determined petitioners were not             
          liable for an addition to tax under section 6651(a)(1).  However,           







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