Lawrence Jay Russ - Page 5




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                        Table 1:  Unpaid Taxes by Year                                
                        Tax Year                     Tax Due                          
                        1998                        $6,577.17                         
                        1999                        11,003.93                         
                        2000                        5,752.52                          
                        2001                        6,053.45                          
                        2002                        3,260.58                          
                        Total                       32,647.65                         
               In response to the notice of Federal tax lien Filing and               
          Your Right to a Hearing Under IRC 6320 sent to him on March 24,             
          2005, petitioner timely submitted a Form 12153, Request for a               
          Collection Due Process Hearing.                                             
               On September 15, 2005, after consulting with petitioner,               
          respondent consolidated the two appeals (the appeal of the                  
          rejection of the OIC and the appeal of the Federal tax lien                 
          filing) with one Appeals Officer (AO).  The AO scheduled a                  
          hearing with petitioner for October 5, 2005.                                
               Before the hearing, the AO analyzed petitioner’s financial             
          situation and determined what expenses were allowable under                 
          Internal Revenue Manual (IRM) guidelines.  Petitioner’s central             
          complaint with the rejection of his OIC was the exclusion of his            
          monthly credit card payments from the expenses allowed in                   
          computing his income available to pay his outstanding tax                   
          liabilities.                                                                
               At the face-to-face conference between petitioner and the AO           
          on October 5, 2005, petitioner sought approval of his OIC and did           
          not challenge the underlying tax liabilities.  The AO explained             






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