Dale L. Oyer, Transferee, et al. - Page 6

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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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