Mark Fowler and Joylyn Souter-Fowler - Page 6

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          offers in compromise were submitted on Form 656, Offer in                   
          Compromise.  Petitioners’ offer was to make monthly payments to             
          satisfy the liabilities.  Petitioners planned to pay a portion of           
          the offer amount from their expected tax refund for 1999.                   
               On May 19, 2000, respondent’s revenue officer advised                  
          petitioners that their offers in compromise could not be                    
          processed until petitioners’ 1999 Federal income tax return was             
          filed.  Under respondent’s procedures, offers are not processed             
          while taxpayers are not in compliance with the internal revenue             
               Petitioners had already filed for an extension of time to              
          file for 1999 because they were awaiting information from third             
          parties to complete the return.  On June 15, 2000, respondent               
          filed two Notices of Federal Tax Lien (NFTL) at the county                  
          recorder’s office in Orange County, California, with respect to             
          the individual and joint tax liabilities.  Respondent sent                  
          petitioners the filed NFTLs and Notices of Right to a Collection            
          Due Process Hearing.  On July 14, 2000, petitioners submitted               
          Form 12153, Request for a Collection Due Process Hearing                    
          (administrative hearing), contesting the NFTLs filed by                     
          respondent and noting the pending offers in compromise.                     
               Sometime in 2001, petitioners’ claims were assigned to                 
          respondent’s Appeals officer.  On June 20, 2001, the Appeals                
          officer and petitioners had a telephone conversation discussing             

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