Concepto del proyecto, volúmenes, niveles y agua.

DECISION

Pursuant to the agreement of the parties in this case, it is ORDERED AND DECIDED:

That the determinations set forth in the Notice of Determination Concerning Collection Action under Section 6320 and/or 6330 issued to petitioner on [insert date of notice of determination], for

petitioner’s [insert type of tax] tax liability for taxable year [insert year], and upon which this case is based, are not sustained.

Judge. Entered: * * * * *

It is hereby stipulated that the Court may enter the foregoing decision. Insert the following paragraphs as applicable:

It is further stipulated that respondent will abate the [insert type of tax] tax liability for taxable year [insert year] on the basis that [e.g., the assessment was not made within the applicable statute of limitations; the statutory notice of deficiency was not sent to petitioner’s last known address and petitioner did not receive it in time to file a Tax Court petition.]

It is further stipulated that respondent will abate the balance of petitioner’s outstanding [insert type of tax] tax liability for taxable year [insert year] on the basis that [e.g., the statute of limitations for collection has expired; the tax liability was discharged in bankruptcy.]

It is further stipulated that respondent will take no further collection action with respect to the [insert type of tax] tax liability for taxable year [insert year].

If the statute of limitations for assessment has not expired include the following paragraph: It is further stipulated that the above-referenced tax liability will be abated without prejudice to respondent’s right to reassess the tax liability for taxable year [insert year] pursuant to the deficiency procedures prescribed in the Internal Revenue Code, to the extent permitted by law.

b. Notice of Determination sustained in full -underlying tax liability not at issue

-no abuse of discretion DECISION

Pursuant to the agreement of the parties in this case, it is

ORDERED AND DECIDED: That the determinations set forth in the Notice of Determination Concerning Collection Action under Section 6320 and/or 6330 issued to petitioner on [insert date of notice of determination], for petitioner’s [insert type of tax] tax liability for taxable year [insert year], and upon which this case is based, are sustained in full.

Judge. Entered:

* * * * * It is hereby stipulated that the Court may enter the foregoing decision.

It is further stipulated that, effective upon the entry of this decision by the Court, petitioner waives the restrictions contained in I.R.C. § 6330(e) prohibiting collection of the [insert type of tax] tax liability (plus statutory interest) until the decision of the Tax Court becomes final.

If Supplemental Notice is issued after remand:

Pursuant to the agreement of the parties in this case, it is

ORDERED AND DECIDED: That the determinations set forth in the Notice of Determination Concerning Collection Action under Section 6320 and/or 6330 issued to petitioner on [insert date of notice of determination], for petitioner’s [insert type of tax] tax liability for taxable year [insert year], and upon which this case is based, as supplemented by the Notice of Determination issued on [insert date of supplemental notice], are sustained in full.

c. Notice of Determination sustained in full -no abuse of discretion

- tax liability not at issue

-IRS agrees to collection alternative outside CDP (e.g., OIC, installment agreement) DECISION

Pursuant to the agreement of the parties in this case, it is ORDERED AND DECIDED:

That the determinations set forth in the Notice of Determination Concerning Collection Action under Section 6320 and/or 6330 issued to petitioner on [insert date of notice of determination], for

petitioner’s [insert type of tax] tax liability for taxable year [insert year)], and upon which this case is based, are sustained in full.

Judge.

Entered: * * * * *

It is hereby stipulated that the Court may enter the foregoing decision.

It is further stipulated that the collection of petitioner’s [insert type of tax] tax liability for taxable year [insert year] shall be closed as currently uncollectible for reason of economic hardship as provided under the conditions specified on Form 53, Report of Currently Not Collectible Taxes. OR

It is further stipulated that collection of petitioner’s [insert type of tax] tax liability for taxable year [insert year] shall be made in accordance with the terms of the [insert date of installment agreement] Installment Agreement entered into between the parties pursuant to the provisions of I.R.C. § 6159. OR

It is further stipulated that collection of petitioner’s [insert type of tax] tax liability for taxable year [insert year] shall be made in accordance with the terms of the [insert date of offer-in-compromise] Offer in Compromise entered into between the parties pursuant to the provisions of I.R.C. § 7122. d. Underlying tax liability properly at issue, no abuse of discretion DECISION

Pursuant to the agreement of the parties in this case, it is ORDERED AND DECIDED:

That the determinations set forth in the Notice of Determination Concerning Collection Action under Section 6320 and/or 6330 issued to petitioner on [insert date of notice of determination], for

petitioner’s [insert type of tax] tax liability for taxable year

[insert year], and upon which this case is based, are sustained [insert “in full” if the underlying tax liability is not adjusted; insert “except as provided herein” if the underlying tax liability is adjusted]. That the tax imposed on petitioner by the Internal Revenue Code for taxable year [insert year] is as follows : Judge. Entered: * * * * *

It is hereby stipulated that the Court may enter the foregoing decision.

It is further stipulated that interest is not included in the above-referenced tax liability, and that interest will be assessed as provided by law on the tax liability.

It is further stipulated that fees and collection costs related to the above referenced tax liability, and interest thereon, are not included in the tax liability and shall remain due and owing.

It is further stipulated that, effective upon the entry of this decision by the Court, petitioner waives the restrictions contained in I.R.C. § 6330(e) prohibiting collection of the tax liability (plus statutory interest) until the decision of the Tax Court becomes final.

Insert if applicable:

It is further stipulated that unassessed additions to tax under I.R.C. § [insert applicable code section] will be assessed as provided by law on the above-referenced tax liability.

Insert any of the following paragraphs as appropriate:

It is further stipulated that the above-referenced tax liability does not include a payment in the amount of [insert amount] that was made on [insert date of payment] and applied to petitioner’s tax liability for taxable year [insert year]. It is further stipulated that the above-referenced tax liability Year [Insert type of tax] Tax Addition to tax I.R.C. § Addition to tax I.R.C. §

does not include petitioner’s withholding credits in the amount of [insert amount] for taxable year [insert year].

It is further stipulated that the above-referenced tax liability does not include an advance payment of estimated tax in the amount of [insert amount] made by petitioner on [insert day of payment] for taxable year [insert year]. It is further stipulated that petitioner is entitled to an overpayment credit in the amount of [insert amount] from his [insert year] tax year which will be applied to petitioner’s tax liability for taxable year [insert year]. It is further stipulated that there are no overpayments due to petitioner for taxable year [insert year].

It is further stipulated that the amount of petitioner’s unpaid [insert type of tax] tax liability for taxable year [insert year] is [insert amount].

e. Underlying tax liability not at issue but adjusted, no abuse of discretion DECISION

Pursuant to agreement of the parties in this case, it is ORDERED AND DECIDED:

That the determinations set forth in the Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330 issued to petitioner on [insert date of notice of determination], for petitioner’s [insert type of tax] tax liability for taxable year [insert year], and upon which this case is based are sustained, except as provided herein.

Judge. Entered: * * * * *

It is hereby stipulated that the Court may enter the foregoing decision.

It is further stipulated that the tax imposed on petitioner by the Internal Revenue Code for taxable year [insert year] is as follows:

Year [Insert type of tax] Tax Addition to tax I.R.C. § Addition to tax I.R.C. §

It is further stipulated that interest is not included in the above-referenced tax liability, and that interest will be assessed as provided by law on the tax liability.

It is further stipulated that fees and collection costs related to the above referenced tax liability, and interest thereon, are not included in the tax liability and shall remain due and owing.

It is further stipulated that, effective upon the entry of this decision by the Court, petitioner waives the restrictions contained in I.R.C. § 6330(e) prohibiting collection of the tax liability (plus statutory interest) until the decision of the Tax Court becomes final.

Insert if applicable:

It is further stipulated that unassessed additions to tax under I.R.C. § [insert applicable code section] will be assessed as provided by law on the above-referenced tax liability.

Insert any of the following paragraphs as appropriate:

It is further stipulated that the above-referenced tax liability does not include a payment in the amount of [insert amount] that was made on [insert date of payment] and applied to petitioner’s tax liability for taxable year [insert year].

It is further stipulated that the above-referenced tax liability does not include petitioner’s withholding credits in the amount of [insert amount] for taxable year [insert year].

It is further stipulated that the above-referenced tax liability does not include an advance payment of estimated tax in the amount of [insert amount] made by petitioner on [insert day of payment] for taxable year [insert year].

It is further stipulated that petitioner is entitled to an overpayment credit in the amount of [insert amount] from his [insert year] tax year which will be applied to petitioner’s tax liability for taxable year [insert year].

It is further stipulated that there are no overpayments due to petitioner for taxable year [insert year]. It is further stipulated that the amount of petitioner’s unpaid [insert type of tax] tax for taxable year [insert year] is [insert amount].

2. Notice of Determination addresses CDP issues and interest abatement