- 8 - national statistical averages. Using $4,644 resulted in petitioners’ estimated monthly expenses exceeding their monthly income by $36 and rendering petitioners ineligible due to their projected inability to make the $100-monthly payments. The Appeals officer rejected petitioners’ offers in compromise. Petitioners requested an in person hearing, but a hearing was not held due to petitioners’ unavailability. On February 21, 2002, respondent issued two separate notices of determination for the individual and joint liabilities sustaining the filing of the notices of Federal tax liens and rejecting petitioners’ offers in compromise. Petitioners timely appealed to this Court for review of respondent’s determinations. OPINION Petitioners contend that the Appeals officer abused his discretion by rejecting their offers in compromise and by sustaining the filing of the Federal tax liens. Section 6320 provides that a taxpayer shall be notified in writing by the Secretary of the filing of a Federal tax lien and provided with an opportunity for an administrative hearing. Sec. 6320(b). Hearings under section 6320 are conducted in accordance with the procedural requirements set forth in section 6330. Sec. 6320(c). When an Appeals officer issues a determination regarding a disputed collection action, section 6330(d) allows a taxpayer toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011