David Ray and Linda Lee Harris - Page 9

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               By letter dated December 27, 2001, petitioners advised the             
          Appeals officer that they disputed that they had been given                 
          credit for all of the payments which they had made toward their             
          1990 income tax liability.  On December 28, 2001, the Appeals               
          officer held a CDP hearing with petitioners.  Additionally, on              
          December 28, 2001, the Appeals officer provided petitioners with            
          a spreadsheet showing where all of their payments toward their              
          1990 tax liability had been applied.                                        
               On or about February 8, 2002, petitioners filed a Form 656,            
          Offer in Compromise (OIC), based upon doubt as to liability.  In            
          their OIC, petitioners again contended that they were not                   
          properly credited for the payments they had made and that they              
          owed less than the amounts shown by the Internal Revenue Service.           
          By letter dated March 25, 2002, the Internal Revenue Service in             
          Milwaukee, Wisconsin, acknowledged that petitioners’ OIC had been           
          received.                                                                   
               Petitioners were advised in a letter dated October 15, 2002,           
          that their OIC had been transferred to the Appeals officer who              
          held their CDP hearing.  The Appeals officer subsequently sent              
          petitioners a letter advising that he had received their doubt as           
          to liability OIC.  On the basis of the determination that                   
          petitioners had been credited for all payments, the Appeals                 
          officer advised petitioners that he was rejecting their OIC.  The           








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