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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 that
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Last modified: May 25, 2011