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In response to the Final Notice, petitioners requested a
hearing pursuant to section 6330(b) (hearing) on August 7, 2000.
On June 8, 2001, Appeals Officer William Smith of the Salt Lake
City, Utah Appeals Office (Appeals Officer Smith) sent a letter
to petitioners scheduling a hearing for July 12, 2001. The
hearing was subsequently postponed because petitioners indicated
that they would file an OIC with respect to their outstanding tax
liabilities.
On July 3, 2001, petitioners submitted an OIC for their
unpaid income tax liabilities for 1991, 1992, 1993, 1994, 1995,
1996, as well as 2000. On a Form 656, Offer in Compromise,
petitioners indicated that Mr. Ashurst had been unemployed since
July of 2000, that he had coronary surgery in August of 1998,
that prevented him from engaging in physical activity, and that
they had exhausted all their resources in seeking employment and
maintaining the household. Petitioners offered to compromise
their tax liabilities of approximately $27,000 for the years 1991
through 1996 and 2000 with a one-time payment of $3,500.
On July 9, 2001, Appeals Officer Smith informed petitioners
that their offer was received and that an Offer examiner would
contact them to evaluate their request. On January 16, 2002,
Bonnie Griggs, a Revenue officer from the Ogden, Utah, Office of
the Internal Revenue Service (Revenue Officer Griggs) sent
petitioners a letter stating that the OIC had been reviewed and
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