- 2 -
Procedure. The decision to be entered is not reviewable by any
other court, and this opinion should not be cited as authority.
The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. Pursuant to section 6330(d), petitioners seek
review of respondent's determination to proceed with collection
of their tax liability of $40,094.22 for 1995. At trial,
petitioners also challenged the amount of interest that has
accrued on their tax liability. The issues for decision are
whether: (1) The Appeals officer abused her discretion in
rejecting petitioners' Offer in Compromise (OIC) and sustaining a
proposed levy to collect petitioners' unpaid income tax
liability; and (2) the Appeals officer should have abated
interest assessed with respect to petitioners' liability for the
1995 tax year.
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioners
resided in Riverside, California, at the time the petition was
filed.
Background
A. Examination of Petitioners' Individual Income Tax Return for
1995
On April 15, 1996, petitioners filed a joint Form 1040, U.S.
Individual Income Tax Return, for 1995. On September 23, 1997,
respondent notified petitioners that their 1995 return had been
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011