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failed to respond to petitioner’s request to abate penalties for
late filing of individual tax returns for 1981-91; (3)
petitioners want to extend the time to assess tax to allow time
to resolve the above issues and to obtain funds to pay taxes due;
and (4) they were entitled to relief on the basis of various
claims relating to employment taxes with respect to petitioner’s
law corporation and the notices of liens filed in 1992 and 1997.
Petitioners stated that they had applied for a loan on real
property, the proceeds of which they would use to pay their tax
liabilities in full.
C. The Section 6330(b) Hearing and Respondent’s Notice of
Determination
On March 8 and April 2, 2002, respondent’s Appeals Office
conducted a hearing on petitioners’ case for tax years 1991,
1993, and 1995. Petitioners attended the hearing. At the
hearing, petitioners offered to obtain a loan on real property to
pay their tax liabilities for the years in issue. Petitioners
did not challenge their underlying tax liability for 1991, 1993,
or 1995 at the hearing. The Appeals officer concluded that
petitioners did not qualify for alternatives to collection, such
as an installment agreement or an offer in compromise, because
petitioners were not currently in compliance with Federal tax
laws and they had not submitted financial information that would
enable respondent to ascertain whether they qualified for any
alternatives to collection once they became compliant.
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Last modified: May 25, 2011