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 aPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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