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In addition to Form 656, Offer in Compromise, petitioner
submitted the following completed forms at the hearing: (1) Form
433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, and (2) Form 433-B, Collection
Information Statement for Businesses. On the Form 433-A,
petitioner indicated that he was an unmarried, self-employed
attorney and had total monthly income and expenses of $2,707 and
$3,302, respectively. On the Form 433-B, petitioner stated that
he had total monthly business income and expenses of $6,131 and
$3,424, respectively.
On October 11, 2002, the Appeals Office sent to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination). In the
notice of determination, the Appeals Office determined the
following:
1. All legal and procedural requirements for filing the
notice of Federal tax lien had been met.
2. Petitioner’s income tax liabilities were timely
assessed, and the assessments were “properly based on established
law, policy and procedure.”
3. Petitioner’s offer-in-compromise was properly rejected,
because petitioner was noncompliant in the payment of both his
income tax liabilities and estimated tax payments, petitioner was
capable of paying more than the amount offered, no exceptional
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Last modified: May 25, 2011