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Filing and Your Right to a Hearing Under IRC 63201 relating to
petitioners’ 1997 tax liability.
On September 21, 2000, petitioners timely filed Form 12153,
Request for a Collection Due Process Hearing, in which they
contended that their 1997 tax liability was satisfied pursuant to
an offer in compromise.
The Appeals officer reviewed the files and transcripts of
account and determined that respondent had not received from
petitioners Form 656, Offer in Compromise, or Form 433-A,
Collection Information Statement for Individuals. On June 12,
2001, the Appeals officer held a hearing with petitioners, during
which she explained to petitioners that settlement of tax
liabilities for less than the amount owed requires the completion
of Form 656. She informed petitioners that a binding settlement
agreement had not been executed between petitioners and the
auditor, but that petitioners could discuss an offer in
compromise or installment agreement relating to petitioners’ 1997
tax liability. Petitioners, however, declined to discuss these
collection alternatives.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
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Last modified: May 25, 2011