- 2 - respondent’s Appeals officer to sustain the lien and reject petitioners' offer to compromise their 1995, 1996, and 1997 liabilities of $7,832.90 for $100. Because of the value of petitioners’ assets, we hold that it was not an abuse of discretion. Background The parties submitted this case fully stipulated under Rule 1221. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners, Mr. Razo and Mrs. Razo, resided in El Paso, Texas, at the time they filed their petition. This Court, in an Order dated November 19, 2003, denied a motion by respondent to dismiss for lack of jurisdiction, as supplemented. Petitioners filed joint Federal income tax returns for 1995, 1996, and 1997. Each of these returns showed tax due, but petitioners did not submit payment with the returns. On March 1, 2002, respondent issued petitioners a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under I.R.C. Section 6320, listing their total 1995, 1996, and 1997 liabilities as $7,832.90. On March 4, 2002, respondent filed a notice of Federal tax lien in El Paso County, Texas. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time the petition was filed, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011