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administration. Petitioners checked the box for “Deferred
Payment Offer (Offered amount will be paid over the life of the
collection statute)”. Petitioners offered to pay the tax
deficiency without paying any penalty or interest. Petitioners
listed the monthly payment as $300 for a total of 27 months.
After submitting the offer in compromise, petitioners
submitted to respondent a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals.
Petitioners listed a total balance in their bank accounts of
$10,466.65. Petitioners also listed owning outright a house
valued at $400,000 and a car valued at $14,000. Petitioners
listed their monthly income as $1,538 and their monthly expenses
as $990.
On November 21, 2001, petitioners timely submitted a Form
12153, Request for a Collection Due Process Hearing, and
requested a hearing with respondent’s Appeals Office.
Petitioners’ stated objections in the Form 12153 concerned the
underlying tax liability for 1991 and the offer in compromise
that they had previously submitted.
Appeals Officer Michael Glyer was assigned petitioners’
case. Appeals Officer Glyer determined that petitioners were not
entitled to contest their underlying tax liability. Appeals
Officer Glyer also reviewed the offer in compromise based on the
financial information submitted by petitioners and determined
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Last modified: May 25, 2011