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late filing and late payment additions to tax and penalties that
respondent had assessed against petitioners relating to
petitioners’ 2000, 2001, and 2002 Federal income tax returns and
warning petitioners of the potential for default on the OIC that
had been entered into if petitioners did not pay the various
additions to tax and penalties that had been assessed against
them.
Specifically, in November 2003, respondent mailed to
petitioners at their Via Chirpia, Mission Viejo, address a notice
alerting petitioners that the OIC was subject to likely
termination if petitioners’ outstanding additions to tax and
penalties for 2001 and 2002 were not paid.
In January 2004, respondent mailed to petitioners (at the
Via Chirpia, Mission Viejo, address) a notice of default on the
OIC, informing petitioners that the OIC was terminated.
On June 18, 2005, respondent mailed to petitioners a notice
of intent to levy and a notice of petitioners’ right to a hearing
relating to the approximate $148,350 balance of petitioners’
unpaid 1993 Federal income taxes.
On July 21, 2005, petitioners filed a Form 12153, Request
for a Collection Due Process Hearing, with regard to respondent’s
notice of intent to levy, in which petitioners requested that
respondent reinstate the OIC.
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Last modified: March 27, 2008