Perry Goldman and Sandra Goldman - Page 2

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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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