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for unpaid Federal income tax and related liabilities for 1992,
1993, 1995, and 1996.2
The issue for decision is whether respondent abused his
discretion by rejecting petitioner’s Form 656, Offer in
Compromise.
Background
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Pasadena, California, at the time
the petition was filed.
Petitioner filed Federal income tax returns for 1992, 1993,
1995, and 1996. For the unpaid tax liability of $7,022 reported
on her 1992 return, petitioner entered into an installment
payment plan with respondent. She made payments of approximately
$100 per month to respondent during 2001, but she stopped making
payments under the plan before paying off the remaining account
balance of $6,146.41, which includes accrued interest and
penalties as of July 1, 2002, for the 1992 taxable year.
On February 1, 2002, respondent issued petitioner a notice
of intent to levy for the 1992, 1993, 1995, and 1996 taxable
years. On March 4, 2002, respondent received petitioner’s Form
2 As of Feb. 1, 2002, the total amount due for the four
taxable years was $20,939.17.
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