- 5 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007