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authority. These cases arise from petitions2 filed under section
6330(d) in response to Notices of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330
(Determination Notices) by petitioners Gerry Ashurst (Mrs.
Ashurst) and Kean H. Ashurst (Mr. Ashurst), wife and husband.
The sole issue for decision is whether the Settlement officer
abused his discretion in rejecting petitioners’ Offer In
Compromise (OIC). We hold he did not.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
LaGrange, Kentucky, at the time they filed the petitions.
Petitioners filed their Federal income tax returns for 1991,
1992, 1993, 1994, 1995, and 1996, reflecting unpaid balances due.
The balances were assessed and, with penalties and accrued
interest, exceed $27,000.
On July 22, 2000, respondent issued a Final Notice - Notice
of Intent to Levy and Notice of Your Right to a Hearing (Final
Notice) with regard to petitioners’ unpaid Federal income tax
liabilities for 1991, 1992, 1993, 1994, 1995, and 1996, totaling
$27,140.
2 These cases have been consolidated for purposes of trial,
briefing, and opinion.
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