Segudino and Delfa Razo - Page 2

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          respondent’s Appeals officer to sustain the lien and reject                 
          petitioners' offer to compromise their 1995, 1996, and 1997                 
          liabilities of $7,832.90 for $100.  Because of the value of                 
          petitioners’ assets, we hold that it was not an abuse of                    
          discretion.                                                                 
          Background                                                                  
               The parties submitted this case fully stipulated under Rule            
          1221.  The stipulation of facts and the attached exhibits are               
          incorporated herein by this reference.  Petitioners, Mr. Razo and           
          Mrs. Razo, resided in El Paso, Texas, at the time they filed                
          their petition.  This Court, in an Order dated November 19, 2003,           
          denied a motion by respondent to dismiss for lack of                        
          jurisdiction, as supplemented.                                              
               Petitioners filed joint Federal income tax returns for 1995,           
          1996, and 1997.  Each of these returns showed tax due, but                  
          petitioners did not submit payment with the returns.  On March 1,           
          2002, respondent issued petitioners a Notice of Federal Tax Lien            
          Filing and Your Right to a Hearing Under I.R.C. Section 6320,               
          listing their total 1995, 1996, and 1997 liabilities as                     
          $7,832.90.  On March 4, 2002, respondent filed a notice of                  
          Federal tax lien in El Paso County, Texas.                                  


               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect at the time the petition was            
          filed, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     





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