Michael A. and Esther N. Milnes - Page 3




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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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