- 3 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011