Joseph G. Dostal - Page 2

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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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