- 15 - Under the various payment options, respondent would be able to file Federal tax liens to protect his interests until such time as the liability is satisfied. Accordingly, respondent’s interest would be protected through the liens while respondent received monthly payments. The result of the Appeals officer’s financial analysis, however, was to deny petitioners’ offers in compromise. To use the national guidelines rather than actual figures in this instance was arbitrary, capricious, and without a sound basis in fact. Petitioners have stated that they are still willing to compromise their tax liabilities for $2,400, but through monthly payments rather than a lump-sum payment.6 Therefore, based on the facts and circumstances of this case, we hold that respondent abused his discretion in denying petitioners’ offer to compromise their tax liabilities for 5(...continued) made in monthly payments over the life of the collection statute. The deferred plan could result in a longer payment period than 24 months. 6 Petitioners and respondent agreed on the amount of the compromise. The only disagreement here is the method of payment. Based on the financial information submitted by petitioners, a payment plan is a reasonable option.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011