- 2 - Collection Waiver, relating to petitioners’ 1982, 1983, 1986, and 1987 tax liabilities. The Form 900 extended, until December 31, 2004, the period of limitations relating to collection of petitioners’ tax liabilities. On January 1, 2000, petitioners and respondent executed a second installment agreement. Petitioners later defaulted on the second agreement. On May 8, 2001, petitioners met with Revenue Officer Shoesmith, with whom they discussed a possible offer-in- compromise and another installment agreement. Shoesmith recommended to her supervisor that respondent reject these collection alternatives because she believed that, among other things, petitioners failed to file returns relating to numerous years, had withheld information relating to their wherewithal to pay, and were trying to avoid paying their taxes. On July 2, 2001, respondent sent petitioners a Notice of Defaulted Installment Agreement Under IRC 6159(b) and a Notice of Intent to Levy Under IRC 6331(d) relating to their 1982, 1983, 1986, 1987, and 1999 unpaid tax liabilities. Petitioners’ 1999 tax liability has been satisfied. On July 16, 2001, respondent received petitioners’ Form 12153, Request for a Collection Due Process Hearing, in which petitioners contended that their outstanding tax liability relates only to 1999, they have been making installment payments, they provided updated financial information, respondent’s revenuePage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011