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petitioner’s Form 656, Offer in Compromise, was an abuse of
discretion. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect for the years in
issue.
Background
Most of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Florida at the time that his petition was
filed.
Petitioner is self-employed and works in the real estate
business. He filed Federal income tax returns for 1986, 1990,
1991, 1992, 1993, 1994, 1995, 1997, and 1999, reflecting unpaid
balances due. The balances were duly assessed, and, with
penalties and accrued interest, the total unpaid liabilities
exceed $78,000. Petitioner did not submit a timely Federal
income tax return for 1998 and did not file any return for that
year prior to May 2002. Petitioner’s Federal income tax returns
for 2001 and 2002 were filed during the pendency of this dispute.
On March 15, 2001, two forms of Final Notice - Notice of
Intent to Levy and Notice of Your Right to a Hearing were sent to
petitioner. One notice related to his liability for 1990, 1991,
and 1992 in the total amount of $27,066.28, and a second notice
related to his liability for 1986, 1993, 1994, 1995, 1997, and
1999, totaling $40,524.01. Petitioner submitted a Request for a
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