- 6 - 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 judicialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011