W. Richard and Janice J. Morgan - Page 6

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          the IRS was precluded from levy while an installment agreement              
          was in effect.                                                              
               The notice of determination was mailed to petitioners on               
          September 15, 2000, in which the Appeals officer determined that            
          the IRS may enforce by levy the 1983 tax lien against assets that           
          were exempt from the bankruptcy.  The determination also stated             
          that, as long as petitioners comply with the terms of the                   
          installment agreement, there would be no collection or levies to            
          collect taxes owing for 1981 and 1982.                                      
               Petitioners contend that they entered into the installment             
          agreement for 1981 and 1982 based on the representation by the              
          IRS that taxes owed for 1983 would be abated, and, therefore,               
          there would be no levy action while the installment agreement was           
          in effect.  Petitioners argue that, absent the representation by            
          the IRS, they would have included the 1983 tax liabilities in the           
          installment agreement.  Petitioners’ position is that the IRS is            
          estopped from levying on petitioners’ assets for the 1983 tax               
          liability while the installment agreement is in effect.                     
               The amount of the tax liability is not in dispute in this              
          case; thus, we shall review respondent’s administrative                     
          determination for an abuse of discretion.  Goza v. Commissioner,            
          114 T.C. 176, 182 (2000).  Equitable estoppel is a judicial                 
          doctrine that precludes a party from denying its own                        

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