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in refusing to accept their offer-in-compromise. In addition,
respondent has, in all other respects, complied with the
requirements of sections 6320 and 6330 so as to be entitled to
proceed with collection of petitioners’ outstanding tax
liabilities for 1991, 1992, 1993, and 1994.
To reflect the foregoing,
An appropriate order and
decision will be entered granting
respondent’s motion for summary
judgment.
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Last modified: May 25, 2011