- 7 - 2000, a letter that Chambers had prepared for petitioners to sign. The letter stated (without explanation) that petitioners requested to withdraw their pending offer in compromise for 1991- 95. Petitioner signed the letter and returned it to Chambers on July 27, 2000. Davis told petitioners that their offer in compromise to settle their liability for 1991-95 was considered withdrawn on July 28, 2000. 2. Administrative Proceedings Under Section 6330(b) Respondent filed a notice of Federal tax lien with respect to petitioners’ 1991-95 Federal income tax liabilities 2 days after petitioners withdrew their offer in compromise. The lien adversely affected petitioner’s credit, including his ability to buy alarm equipment on credit to install for his customers. On August 2, 2000, petitioners timely filed a request for a collection due process hearing. On dates not stated in the record: (a) Petitioner asked respondent’s employees (not identified in the record) why respondent had filed a Federal tax lien; (b) petitioner was told that he had not resubmitted an offer in compromise; (c) petitioners submitted to respondent a offer in compromise that Holder had helped to prepare; (4) respondent did not accept it because petitioners had not filed all tax returns that were due; and (5) petitioners prepared returns that were due and submitted them with the offer in compromise.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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