Randall G. Van Vlaenderen - Page 2

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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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