- 4 - monthly installment payments over 60 months and pay off the full cumulative total of the taxes petitioner owed for 1990, 1991, and 1992 (the years to which respondent’s levy relates) as well as for 1993 through 1999, a cumulative total of $91,120. Respondent’s Appeals officer also noted that for the prior 10 years petitioner had a poor compliance history with regard to the filing and payment of his Federal income tax liabilities and that petitioner, as of July 3, 2001, still was not current with regard to his Federal income tax liabilities (namely, petitioner’s 2000 Federal income tax return had not yet been filed, and petitioner’s estimated tax payments for 2001 were not current). On July 3, 2001, respondent’s Appeals officer discussed on the telephone with petitioner’s representative petitioner’s offer in compromise and explained that the offer in compromise could not be approved because petitioner’s financial information did not demonstrate a genuine doubt as to collectibility of the taxes owed and because of petitioner’s then current and long history of delinquency with regard to his Federal income tax liabilities. On July 18, 2001, petitioner filed with respondent’s Appeals Office his 2000 Federal income tax return and additional financial information. Respondent’s Appeals officer reviewed the additional financial information submitted by petitioner and concluded thatPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011