Debra L. Streck and Donald W. Streck - Page 7

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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          dated August 1, 1993, was withdrawn by petitioners, and two                 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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