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The primary issue for decision is whether respondent’s
Appeals Office abused its discretion in sustaining a notice of
intent to levy relating to petitioners’ outstanding 1993 Federal
income taxes.
Background
The facts of this case have been submitted fully stipulated
under Rule 122 and are so found.
At the time the petition was filed, petitioners resided in
Orange County, California.
Petitioners have a history of failing to timely pay
estimated Federal income taxes due and failing to timely file
their Federal income tax returns.
On April 24, 1998, petitioners and respondent agreed on an
offer-in-compromise (OIC) on the grounds of doubt as to
collectibility relating to approximately $148,350 in petitioners’
unpaid 1993 Federal income taxes.1 Among other things,
respondent’s acceptance of petitioners’ OIC was contingent on
petitioners’: (1) Paying, within 60 days of respondent’s
acceptance of the OIC, to respondent $10,000 (OIC amount);
(2) timely filing Federal income tax returns that became due
during the 5-year period subsequent to their entering into the
1 Because of a credit offset, petitioners’ outstanding
Federal income tax liability for 1995 (including interest,
penalties, additions to tax, and interest) has been paid in full,
and any issue herein relating to 1995 is now moot.
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Last modified: March 27, 2008