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By letter dated December 27, 2001, petitioners advised the
Appeals officer that they disputed that they had been given
credit for all of the payments which they had made toward their
1990 income tax liability. On December 28, 2001, the Appeals
officer held a CDP hearing with petitioners. Additionally, on
December 28, 2001, the Appeals officer provided petitioners with
a spreadsheet showing where all of their payments toward their
1990 tax liability had been applied.
On or about February 8, 2002, petitioners filed a Form 656,
Offer in Compromise (OIC), based upon doubt as to liability. In
their OIC, petitioners again contended that they were not
properly credited for the payments they had made and that they
owed less than the amounts shown by the Internal Revenue Service.
By letter dated March 25, 2002, the Internal Revenue Service in
Milwaukee, Wisconsin, acknowledged that petitioners’ OIC had been
received.
Petitioners were advised in a letter dated October 15, 2002,
that their OIC had been transferred to the Appeals officer who
held their CDP hearing. The Appeals officer subsequently sent
petitioners a letter advising that he had received their doubt as
to liability OIC. On the basis of the determination that
petitioners had been credited for all payments, the Appeals
officer advised petitioners that he was rejecting their OIC. The
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Last modified: May 25, 2011