- 3 - offer-in-compromise. When the Appeals officer determined that petitioner was not eligible for an offer-in-compromise, the possibility of petitioner’s paying his tax liability through an installment agreement was discussed. The Appeals officer and petitioner negotiated a proposed installment agreement under which petitioner was to make biweekly payments of $370 until the unpaid tax liability was paid in full. Entering into this agreement was conditioned upon petitioner’s timely filing of a 2003 tax return. Petitioner also signed a Form 2159, Payroll Deduction Agreement, which permitted respondent to withdraw automatically biweekly payments from petitioner’s wage payments beginning on May 21, 2004. Between March 22 and April 15, 2004, the Appeals officer contacted petitioner several times to notify him of his need to file his 2003 tax return to be eligible for the installment agreement. However, petitioner did not file his 2003 tax return by April 15, 2004. On July 13, 2004, respondent issued a Notice of Determination proposing a levy on petitioner’s assets. On August 11, 2004, petitioner timely filed his petition with this Court, challenging the amount assessed and requesting an installment agreement. On April 28, 2005, respondent filed the motion for summary judgment. Petitioner did not respond to the motion.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011