Ralph M. and Rosemary L. Conlon - Page 6

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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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