Thomas and Julia Bo - Page 7

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          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          withdrawn on July 28, 2000.                                                 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.                                          






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