- 7 - 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offer was in the amount of $2,000.9 On February 10, 1994, the original offer in compromise, dated August 1, 1993, was withdrawn by petitioners, and two revised offers were executed and submitted on Forms 656.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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