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the OIC was rejected because petitioners could pay their tax
liabilities in full.
On January 3, 2003, petitioners filed petitions with this
Court in response to the Determination Notices. A trial hearing
was held on September 8, 2003, in Louisville, Kentucky, at which
petitioners contested respondent’s rejection of their OIC, stated
that their circumstances have changed dramatically, and asked the
Court to remand their case to Appeals for a reconsideration of
their offer.
By order dated November 13, 2003, this Court remanded
petitioners’ 1991, 1992, 1993, 1994, 1995, 1996, and 2000, income
tax years to the Commissioner for the purpose of considering
petitioners’ OIC, taking into consideration petitioners’ change
in circumstances. The order also allowed petitioners, if they
wished to do so, to offer another collection alternative pursuant
to section 6330(c)(2)(A)(iii). The parties were to inform the
Court of the outcome of these proceedings by January 15, 2004.
Pursuant to the order, petitioners submitted additional
information to respondent, including an updated itemization of
income and expenses as well as other financial documents.
On December 30, 2003, after a reconsideration of
petitioners’ financial information, Settlement Officer John N.
Brandon, Jr., of the Louisville, Kentucky, Appeals Office
(Settlement Officer Brandon) sent petitioners a letter rejecting
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Last modified: May 25, 2011