Joe Nathan Wright and Lola H. Wright - Page 3

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          regarding their 1993 and 1994 tax liabilities.  By that time,               
          petitioners had made additional payments of $20,000 in respect of           
          their 1993 tax liability and $500 in respect of their 1994 tax              
          liability.  Respondent rejected petitioners’ initial offer in               
          compromise in March 1996.  During the period from March 1996 to             
          October 1998, petitioners submitted several additional and                  
          revised offers in compromise, none of which respondent accepted.1           
          During that same period, petitioners made aggregate payments of             
          $4,500 in respect of their 1993 tax liability and received an               
          additional $1,476 credit with respect thereto.                              
          Petitioners’ Requests for Abatement                                         
               In a letter addressed to Revenue Officer Melvin Chappell               
          dated September 13, 1997, petitioners requested abatement of                
          additions to tax asserted by respondent with respect to their               
          1993 and 1994 taxable years.                                                
               On October 8, 1998, petitioners filed separate Forms 843,              
          Claim for Refund and Request for Abatement, with respect to their           
          1993 and 1994 taxable years.  On the Forms 843, petitioners                 
          requested abatement of both interest and additions to tax.  In a            
          letter submitted with the Forms 843, petitioners claimed that               
          such interest and additions to tax resulted from unreasonable               


               1  Petitioners maintain that they submitted a total of five            
          offers in compromise.  Respondent maintains that petitioners                
          submitted three offers in compromise and two revised or amended             
          offers.  For the sake of clarity, we treat petitioners’                     
          submissions as five separate offers in compromise.                          




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