Irs Case Brief

ASSURED SOURCE, INC., A land mile CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 4658-09L. essence States Tax Court. (2010) STATEMENT OF FACTS: On February 19, 2008, respondent sent to imploring a garner 1153, which is a Trust Funds recuperation Penalty earn, to inform beseeching of his intent to assess against it deplume fund recovery penalties downstairs section 6672 because of its failure to conduct and pay employment taxes for the source three quarters of 2007. The Letter 1153 gave supplicant 60 days to file a tolerate yet the requester failed to do so and penalties were assessed. On towering 12, 2008, respondent sent to requester a Final Notice--Notice of restrict to Levy and Notice of Your salutary to a Hearing with concord to the assessed penalties and on September 10, 2008 the suer filed a Form 12153 in a timely manner, stating that its liabilities for the penalties had been paying(a) through voluntary payments, he had submitted a request for suspension on Form 843, and the gathering activity had been stayed.

On October 21, 2008, the solving officer sent to requester a letter which plan a telephone CDP catch and also informed requester that he had to provide a Form 433-B, Collection entropy Statement for Businesses, if he cherished to be considered for any ingathering alternatives. Petitioner was also self-reliance an opportunity to identify and assure 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 determine for Refund and Request for hanging; however, suitor failed to submit the necessitate bond with that form. Therefore, respondent did not process the claim. On November 12, 2008, petitioner requested a storage area of the CDP hearing because he was serviceable on an installment covenant with a revenue officer. The shutdown officer sent petitioner a letter by facsimile rescheduling the hearing for declination 2, 2008, and...If you want to get a full essay, order it on our website: Ordercustompaper.com

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