Johnny and M. Suzan Black - Page 3

               Respondent issued petitioners a Notice of Determination                
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          (notice of determination), in which respondent sustained the                
          filing of a Federal tax lien with respect to petitioners’ tax               
          liabilities for 1996, 1997, 1999, 2000, 2001, and 2002.                     
          Respondent rejected petitioners’ offer of $5,000 to compromise              
          their total unpaid tax liability of $26,655.07.                             
               The issue for decision is whether respondent abused his                
          discretion by rejecting petitioners’ offer in compromise (OIC)              
          and by sustaining the filing of the Federal tax lien.                       
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and attached exhibits are                  
          incorporated by this reference.  Petitioners resided in                     
          Riverside, California, at the time the petition was filed.                  
               Petitioners filed Federal income tax returns for 1996, 1997,           
          1999, 2000, 2001, and 2002.  There was some withholding with                
          respect to these years, but the withholding was less than the               
          respective tax liabilities reported.  There were no payments                
          remitted with any of the returns filed.2  Sometime in 1999,                 
          petitioners began making monthly payments of $250 per month with            

               2  It appears that at some point petitioners paid $1.00 for            
          the taxable year 2000.                                                      

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