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their individual Federal income tax liabilities for the years
1983 through 1992 and their liability for withholding taxes
attributable to Jamie Enterprises, Inc. (JEI), a corporation
owned by Mrs. Streck. This offer was in the amount of $2,000.9
On February 10, 1994, the original offer in compromise,
dated August 1, 1993, was withdrawn by petitioners, and two
revised offers were executed and submitted on Forms 656. The
first Form 656 related to petitioners' individual income tax
liabilities for 1983 through 1992. Petitioners offered to settle
these liabilities for $19,000. The second Form 656 was submitted
by Mr. Streck on behalf of JEI to compromise its employment taxes
for 1991 and 1992 for $1,000.
OPINION
Petitioners' primary position is that they have previously
entered into a binding settlement agreement with respondent
regarding the years in issue. They allege that the agreement was
entered into when respondent's Appeals Officer accepted their
offer in compromise prior to the issuance of the notice of
deficiency. It is not clear which of the two Forms 656 relating
to their individual income taxes petitioners rely on.
9Petitioners had a case before this Court with respect to
their 1987 tax year. On Oct. 19, 1993, pursuant to an agreement
by the parties, this Court entered its decision that there was no
deficiency and no additions to tax with respect to the 1987 tax
year.
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