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question regarding ownership of real estate in which an equity
interest of nearly $40,000 appeared to exist. As a result, the
settlement officer concluded that petitioners’ offer in
compromise was not acceptable.
Although petitioners continue to assert that the real
estate belongs to petitioner’s mother, petitioners failed to
provide to respondent’s settlement officer certain requested
information in support of this assertion. For example,
petitioners failed to provide information relating to the
proceeds of the Nashville house that petitioners sold,
information that is particularly significant because of the
$10,532.33 deposit into petitioner’s mother’s bank account on the
same day that the cashier’s check used for part of the
downpayment on the real estate was purchased. Moreover, the
information petitioners provided to the settlement officer showed
that the real estate was originally titled in petitioners’ names,
that petitioners transferred title for no consideration, that
petitioners lived there, and that petitioners paid the property
taxes and mortgage payments.
Generally, when challenging a levy action, taxpayers bear
the responsibility of providing relevant information.
Rule 142(a). The information petitioners provided to the
settlement officer was insufficient to resolve the question
regarding ownership of the real estate. We find no abuse of
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