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On the same day as the dismissal of their chapter 11
bankruptcy case, petitioners filed a petition for chapter 7
bankruptcy relief. Petitioners were granted a discharge in their
chapter 7 bankruptcy case on June 11, 1998.
On August 29, 1998, notices of Federal tax lien were filed
for petitioners’ income tax liabilities for tax years 1991, 1992,
and 1993.
On or about October 30, 1998, the Internal Revenue Service
(IRS) received from petitioners: (1) A request for an
installment agreement (Request for an Installment Agreement), (2)
financial statements, and (3) an offer in compromise (Offer in
Compromise).
The Request for an Installment Agreement covered: (a)
Income tax liabilities for tax years 1994, 1995, 1996, and 1997;
and (b) Form 940, Employer’s Annual Federal Unemployment Tax
Return, and Form 941, Employer’s Quarterly Federal Tax Return,
tax liabilities for tax periods ended March 31, June 30,
September 30, December 31, 1994, March 31, June 30, September 30,
December 31, 1995, March 31, June 30, and December 31, 1996.
The Offer in Compromise was based on “doubt as to liability”
and covered: (a) Income tax liabilities for tax years 1991,
1992, and 1993; and (b) the Trust Fund Recovery Penalty, see
section 6672, for tax periods ended December 31, 1993, March 31,
and June 30, 1994. As grounds for the Offer in Compromise,
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