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Petitioner did not petition this Court to redetermine any of the
tax liabilities, and the underlying tax liabilities are not in
dispute.
Petitioner married during 1997, and on February 10, 1997, he
and his wife purchased a residence as tenants by the entireties.
Petitioner contributed $50,000, or one-half of the downpayment.
Between October 25, 1994, and December 2, 1997, respondent
assessed tax and additions to tax against petitioner for 1993,
1995, and 1996, based on audit examinations and amounts shown as
due on income tax returns. On December 3, 1997, petitioner sent
respondent a Form 656, Offer-in-Compromise (first offer), based
on doubt as to collectibility for the subject years, offering to
settle the total outstanding tax liabilities for $16,209. At
that time, petitioner’s outstanding and unpaid tax liability was
$26,266.06. Petitioner on Form 433-A, Collection Information
Statement for Individuals, claimed that he had a 50-percent
interest in his home and monthly net business income and living
expenses of $1,400 and $1,648, respectively. On February 13,
2001, respondent sent petitioner a notice rejecting petitioner’s
first offer, stating that the amount owed was legally due and
appeared to be collectible.
On September 5, 2001, petitioner submitted a second offer-
in-compromise (second offer) for the subject years, this time for
$2,200. In the second offer, petitioner’s only reference to his
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