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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.
Background
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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Last modified: May 25, 2011