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unless stated otherwise.) The issue for decision is
whether the Appeals officer who made the determination
abused her discretion by rejecting an offer-in-compromise
made on petitioner’s behalf.
Background
The facts set out herein are taken from the
stipulation of facts filed by the parties and the exhibits
referred to therein. The stipulation of facts and the
exhibits filed by the parties are incorporated herein.
Petitioner resided in the State of Washington at the time
his petition in this case was filed.
Petitioner filed his separate individual income tax
return for taxable year 2000 on or about October 15,
2001, wherein he reported total tax of $137,465 and zero
payments. As of March 13, 2003, petitioner owed
$143,165.96 with respect to taxable year 2000.
Petitioner filed his separate individual income tax
return for taxable year 2001 on or about October 12, 2002.
In that return, he reported total tax of $51,622 and
Federal income tax withholding of $10,692, for balance
owing of $40,930. As of March 13, 2003, petitioner owed
$45,675.28 with respect to taxable year 2001. Petitioner’s
tax returns for taxable years 2000, 2001, 2002, and 2003
are summarized in the appendix hereto.
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