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tax liabilities. Petitioners’ objection to respondent’s motion
was presented at a hearing on December 1, 2003. Petitioners
contend that there was an abuse of discretion because
respondent’s Appeals officer refused to discharge or release the
Federal tax lien, notice of which has been filed, with respect to
certain real property. Petitioners resided in Florida at the
time they filed their petition.
Background
Petitioners’ 1991, 1992, 1993, and 1994 income tax returns
were examined, and respondent determined income tax deficiencies
in each year. Petitioners petitioned this Court with respect to
the 1991, 1992, and 1993 years and, eventually, entered into an
agreed decision that was entered on July 16, 1998. With respect
to the 1994 year, petitioners attempted to petition this Court,
but the matter was dismissed for lack of jurisdiction. Based on
these events, petitioners’ 1991, 1992, 1993, and 1994 income tax
deficiencies were assessed.
Respondent sent petitioners a Notice of Federal Tax Lien
Filing And Your Right To A Hearing Under I.R.C. section 6320,
dated March 27, 2002, advising that a Notice of Federal Tax Lien
had been filed on March 22, 2002. Prior to the filing of the
notice, petitioners submitted several offers-in-compromise with
respect to doubt as to collectibility of the outstanding
assessments. The offers were rejected because it was determined
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