Carl and Lisa Neugebauer - Page 7

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               The Appeals officer satisfied the second requirement by                
          considering the issues raised by petitioners.  The only issue               
          raised by petitioners was their inability to pay the liability in           
          full and, in that regard, petitioners requested that they be                
          allowed to satisfy the liability through an offer in compromise.            
          The Appeals officer addressed this request by reviewing the                 
          information submitted, explaining that it was incomplete, and               
          asking for additional information.  Petitioners failed to submit            
          a properly completed Form 656, Offer in Compromise, and the                 
          required financial information for the consideration of their               
          request.                                                                    
               As to the third requirement, the Appeals officer properly              
          balanced the need for efficient collection of taxes through the             
          proposed levy against the concern that any collection action be             
          no more intrusive than necessary.  Petitioners failed to provide            
          the information required in order to consider an alternative                
          collection action.                                                          
               Throughout the proceeding, petitioners’ conduct demonstrates           
          propensity to delay the collection of their outstanding tax                 
          liabilities.  We sustain respondent’s determination regarding the           
          proposed levy as a permissible exercise of discretion.  We note             
          as to the allegations set forth in the petition that petitioners            
          did receive a hearing under section 6330, that petitioners were             
          given an opportunity to participate in an offer in compromise,              






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