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relating to petitioner’s 1988-89 tax years. On November 16,
1999, petitioner filed a Request for a Collection Due Process
Hearing, Form 12153, related to her 1989 tax year in which she
stated that she wanted respondent to consider her offer in
compromise for that year. In her request for a hearing, she said
that she had health and financial difficulties.
Respondent’s Appeals officer, J. Chris Neighbor (Neighbor),
reviewed petitioner’s request for a hearing and her offer in
compromise. On February 18, 2000, Neighbor told petitioner by
letter that respondent would not consider her offer in compromise
because she had not filed returns for 1991-98. Neighbor
scheduled a hearing for March 14, 2000, to review petitioner’s
tax liabilities for 1988-891 and asked her to let him know within
10 days if she preferred a different date. He also asked
petitioner to give him the following items: (1) A financial
statement for petitioner and her business; (2) signed income tax
returns for 1991-98; (3) petitioner’s most recent mortgage
statement showing the remaining balance and the amount of the
monthly payment; and (4) information about Silvia International
Realty, such as whether it produces income and has employees.
Neighbor sent blank financial statement forms for petitioner to
complete.
1 Respondent apparently assumed petitioner requested a
hearing under sec. 6330(b) for both 1988 and 1989, even though
her request only stated 1989.
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Last modified: May 25, 2011