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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
not.
Background
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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