123 T.C. No. 1
UNITED STATES TAX COURT
KEITH AND CHERIE ORUM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18317-02L. Filed July 1, 2004.
Ps filed joint Federal income tax returns for 1998
and 1999 but did not make full payment of the tax
liabilities. On June 23, 2000, R sent Ps by certified
mail a Notice of Intent to Levy and Notice of Your
Right to a Hearing for 1998. Ps did not file a sec.
6330, I.R.C., hearing request in response to this
notice. On Dec. 14, 2001, R sent Ps a Notice of Intent
to Levy and Notice of Your Right to a Hearing for 1998
and 1999. P sent R a sec. 6330, I.R.C., hearing
request dated Dec. 31, 2001, for 1998 and 1999.
In February 2002, Ps submitted an offer-in-
compromise. R rejected the request on the basis of
financial information submitted by Ps.
R granted Ps an equivalent hearing for 1998 and a
sec. 6330, I.R.C., hearing for 1999. During the
hearings, R requested additional financial information
from Ps by Aug. 9, 2002, to consider an installment
agreement. Ps failed to timely provide the additional
information. R issued a decision letter for 1998 and a
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