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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 revenue
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Last modified: May 25, 2011