- 2 - 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 determinedPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011