Irs Case Brief

ASSURED SOURCE, INC., A MICHIGAN CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 4658-09L. marriage States Tax Court. (2010) STATEMENT OF FACTS: On February 19, 2008, respondent sent to appeal a garner 1153, which is a Trust Funds recuperation Penalty letter, to inform supplicant of his intent to assess against it entrust fund recovery penalties under section 6672 because of its failure to keep up and pay employment taxes for the first three quarters of 2007. The Letter 1153 gave supplicant 60 days to file a stand up yet the requester failed to do so and penalties were assessed. On noble 12, 2008, respondent sent to petitioner a Final Notice--Notice of contain to Levy and Notice of Your Right to a Hearing with say to the assessed penalties and on September 10, 2008 the petitioner filed a Form 12153 in a timely manner, stating that its liabilities for the penalties had been paid through voluntary payments, he had submi tted a request for abatement on Form 843, and the assembly activity had been stayed.

On October 21, 2008, the solving officer sent to petitioner a letter which scheduled a telephone CDP hark and also informed petitioner that he had to provide a Form 433-B, Collection Information Statement for Businesses, if he valued to be considered for any collection alternatives. Petitioner was also given an opportunity to identify and substantiate any payments of the penalty assessments and was offered a face-to-face hearing. Petitioner submitted to the IRS a Form 843, which is a field of view for Refund and Request for Abatement; however, petitioner failed to submit the needed bond wit h that form. Therefore, respondent did not p! rocess the claim. On November 12, 2008, petitioner requested a postponement of the CDP hearing because he was usable on an installment agreement with a revenue officer. The stop officer sent petitioner a letter by facsimile rescheduling the hearing for December 2, 2008, and...If you want to get a full essay, order it on our website: OrderEssay.net

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