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actions. In the notices, respondent also determined that
petitioners’ offers in compromise based on doubt as to liability
were unacceptable because each petitioner’s underlying tax
liability was based on a Tax Court decision and because each
petitioner was noncompliant with income tax filing requirements.
In the notices, respondent determined that all applicable legal
and administrative procedures had been met and that collection
actions could proceed against petitioners.
H. The Petitions
On July 18, 2002, petitioners filed with the Court
substantially identical petitions challenging the notices.5 In
the petitions, petitioners challenge their transferee tax
liabilities and also challenge the Appeals officer’s rejection of
their offers in compromise.
I. Respondent’s Motions for Summary Judgment
On January 31, 2003, respondent filed substantially
identical motions for summary judgment in each petitioner’s case.
On February 13, 2003, petitioners filed substantially identical
responses opposing respondent’s motions for summary judgment in
each case. On February 24, 2003, the Court held a hearing in
5 When these petitions were filed, Dale Oyer resided in
Kansas City, Missouri, and Shirley Oyer resided in Shawnee,
Kansas. The petitions for Acme Leasing Trust and ABC Seamless
Trust each listed the same Kansas City, Missouri, mailing
address.
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