- 6 - month for 18 months, with the remaining amount of their income tax liability to be paid at the end of the 18-month period. At the time that petitioners proposed this installment agreement to Riley, Riley had determined that the total amount of their unpaid tax liabilities was $645,537. This figure included the reported but unpaid income tax liability on petitioners’ joint Federal income tax return for 1999 and trust fund penalties that had been imposed against each of them for 1991. Based upon the financial information petitioners submitted to Riley, she determined that petitioners had the ability to pay the total amount of their unpaid tax liabilities sooner than the amount of time requested in the proposed installment agreement. Accordingly, Riley rejected petitioners’ proposed installment agreement. On September 19, 2001, petitioners also submitted a Form 9423, Collection Appeal Request, in which they requested that respondent not file a Federal tax lien. Petitioners provided, in pertinent part, the following explanation for their request: Taxpayer is working to sell the assets reported on Forms 433-A and 433-B * * *. Taxpayer believes that a substantial portion of such assets can be sold by December 31, 2001 and that all can be disposed of within the next twelve months. These sales would provide funds to satisfy the tax liability in question. Filing a tax lien would materially reduce the market value of the assets to be sold and cause the banks to call loans on which most of these assets are pledged. That would put the taxpayer out of business with no resources to pay the tax liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011