- 7 - 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.Page: 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