Ralph M. and Rosemary L. Conlon - Page 3

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          for unpaid Federal income tax and related liabilities for 1991.             
               The issues for decision are:                                           
               (1) Whether petitioners may challenge the existence or                 
          amount of their underlying tax liability for 1991.  We hold that            
          they may not.                                                               
               (2) Whether respondent abused his discretion in refusing to            
          accept petitioners’ offer in compromise.  We hold that he did               
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in Canyon Country, California, at the           
          time that their petition was filed with the Court.                          
               On October 16, 1992, petitioners jointly filed a Form 1040,            
          U.S. Individual Income Tax Return, for 1991.  The address given             
          on the 1991 return was 27424 Sand Canyon Road, Canyon Country,              
          California, 91351 (Sand Canyon Road address).  Petitioners also             
          used the Sand Canyon Road address for the filing of their 1992              
          tax return.                                                                 
               On or about June 23, 1993, respondent notified petitioners             
          that their 1991 tax return had been selected for examination.               
               During the examination of petitioners’ 1991 income tax                 
          return, petitioners signed and filed with the Internal Revenue              
          Service a Form 2848, Power of Attorney and Declaration of                   
          Representative, naming Bruce M. Mark (Mr. Mark) as their                    

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