William C. Eberhardt, Jr. and Susan A. Eberhardt - Page 9

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               On February 7, 2002, respondent issued a Final Notice,                 
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          (Notice of Intent to Levy), with respect to petitioners' taxable            
          year 1995.  On February 27, 2002, in response to the Notice of              
          Intent to Levy, respondent received petitioners' Form 12153,                
          Request for a Collection Due Process Hearing (hearing).                     
          E.  Petitioners' Section 6330 Hearing                                       
               Appeals Officer Wendy Clinger (Ms. Clinger) was assigned to            
          handle petitioners' hearing.  Petitioners met with her for their            
          hearing on November 21, 2002.                                               
               During the hearing, petitioners disputed their underlying              
          tax liability.  Ms. Clinger advised them that they had already              
          had an opportunity to challenge the liability when they had a               
          trial before the Tax Court and could not do so again in the                 
          hearing.  Ms. Clinger explained that petitioners could discuss              
          the collection alternatives available to petitioners to satisfy             
          their tax liability.                                                        
               At the hearing, petitioners submitted an OIC offering $1,000           
          to satisfy their outstanding 1995 tax liability which totaled               
          over $49,000, including accumulated interest.  The $1,000 would             
          be paid within 90 days of written acceptance of their OIC.                  
          Petitioners requested that their OIC be accepted in the interests           
          of effective tax administration, or doubt as to collectibility.             








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