- 4 -
an attorney and attached Mr. Crisan’s Form W-2, Wage and Tax
Statement, for 2001, which reported $119,120 of wages, tips, and
other compensation.
During a telephone conversation on April 29, 2002, the
Appeals officer requested again that petitioners provide an offer
of a monthly installment amount to pay off the tax liabilities.
On May 13, 2002, Mr. Crisan sent the Appeals officer a letter
requesting a 2-week extension of time, stating that he was unable
to commit to a monthly payment amount because he wanted to review
his pension plan policies. Other than the proposed installment
payment amount of $100 per month, petitioners never made a formal
offer of an installment agreement and sent no further information
or correspondence to respondent.
On June 12, 2002, respondent sent petitioners a notice of
determination for the years in issue. Respondent sustained the
levy action, stating:
We have determined that no relief is to be granted in
this case. You have requested that the liability at issue
be resolved via an offer in compromise. However, your
financial data indicate that you can satisfy the liability
by liquidating assets or with an installment agreement.
Your request for additional time to consider your options is
unrealistic and is denied. Appeals believes that the need
for efficient collection of taxes has been balanced with
your concern for the intrusiveness of the proposed
assessment.
Further, respondent explained:
An offer in compromise, doubt as to collectibility is
not appropriate as the taxpayers have the assets to
immediately full [sic] pay the tax liability. In addition,
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011