- 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