- 2 - 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 theirPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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