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Since approximately 1990, Douglas W. Coy has served as
petitioner’s accountant. Mr. Coy has prepared petitioner’s tax
returns for all the tax years in which he has represented
petitioner.
Petitioner’s Offer-in-Compromise
On October 31, 1995, petitioner and respondent entered into
an offer-in-compromise. The offer-in-compromise related to
income tax liabilities for 1983, 1984, 1985, 1986, 1987, 1988,
1989, 1990, and 1991, and trust fund recovery penalties for
unpaid employment taxes for periods ending March 31, June 30, and
September 30, 1988, June 30 and December 31, 1989, and March 31,
June 30, and September 30, 1990. The offer-in-compromise was
submitted on the basis of doubt as to collectibility. The amount
of individual income tax and statutory additions compromised
totaled $989,475.2 Petitioner offered to pay $100,000 to
2 The trust fund recovery penalties to be compromised under
sec. 6672 were $102,030. By order dated Oct. 21, 2002, the Court
granted respondent’s motion to dismiss for lack of jurisdiction
and to strike as to the trust fund penalties. The parties agree:
The doctrine of collateral estoppel will apply to
prohibit the Respondent, as well as the Petitioner,
from re-litigating the Petitioner’s appeal of the
Notice of Determination in the District Court if the
Tax Court decides whether the Respondent abused his
discretion in proceeding with collection of tax
liabilities previously compromised prior to a decision
of that issue by the District Court.
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