-2- judgment under Rule 121(a). Petitioners responded to respondent’s motion under Rule 121(b). We shall grant respondent’s motion for summary judgment. Section references are to the applicable versions of the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. Background Petitioners filed joint Federal income tax returns for 1994 and 1995 reflecting refunds for both years. These returns were later audited, and on or about April 19, 1999, respondent assessed income tax deficiencies and related penalties and interest against petitioners with respect to 1994 and 1995. Petitioners failed to pay fully the amounts assessed and in February 2000 ceased making monthly payments of $2,500 per month as mandated by an installment payment agreement. On or about May 7, 2001, respondent issued to petitioners a letter entitled “Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing Under IRC 6330". On or about June 8, 2001, petitioners submitted a Form 12153, Request For A Collection Due Process Hearing. On January 10, 2002, petitioners submitted an offer in compromise and a collection information statement in connection with their request for a hearing. Respondent’s Appeal officer determined that the offer in compromise should not be accepted because the offer andPage: Previous 1 2 3 4 5 6 7 8 Next
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