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petitioners ABC Seamless Trust and Acme Leasing Trust. On August
14, 2001, the Appeals officer held an in-person hearing with
respect to the collection proceedings against petitioners Dale
Oyer and Shirley Oyer.
On or about November 12, 2001, each petitioner submitted to
the Appeals officer an offer in compromise based on doubt as to
liability. In these offers in compromise, each petitioner
offered to pay $50 to compromise the unpaid balance of assessment
of transferee tax liability.
In addition, each petitioner submitted to respondent
substantially identical documents dated November 15, 2001, and
captioned “Amendment to Request for a Collection Due Process
Hearing”. In these documents, petitioners alleged that in
determining their transferee liabilities, respondent had failed
to take into consideration certain “additional liabilities” of
the corporation that petitioners contended would more than offset
the value of any assets that the corporation transferred to them.
G. Respondent’s Notices of Determination
On June 13, 2002, respondent issued to each petitioner a
Notice of Determination Concerning Collection Action(s) Under
Sections 6320 and/or 6330 (the notices). In the notices,
respondent determined that petitioners could not challenge their
underlying tax liabilities in these collection proceedings
because these liabilities had been determined in prior judicial
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Last modified: May 25, 2011