David Jackson and Betty S. Jackson - Page 5

                                        - 4 -                                         
               On April 25, 2002, respondent’s Ogden Service Center                   
          received from petitioners a Form 656, Offer in Compromise (OIC),            
          offering $10,000 to satisfy their income tax liabilities for the            
          years in issue.  Petitioners attached to the OIC a statement                
          stating, in part:  “We are not able to pay the entire amount                
          owed, but we are refinancing our current assets, borrowing from             
          friends and family and will use our income to pay the amount we             
          are offering.”                                                              
               Although the record does not definitively disclose what                
          events have transpired since April 2002, it appears that on or              
          about March 27, 2003, petitioners requested from respondent a               
          payoff amount.  In response, petitioners received from respondent           
          computer printouts dated March 27, 2003, for each of the years in           
          issue reflecting their names and Social Security numbers, account           
          balance, accrued interest, and accrued additions to tax as of               
          April 7, 2003.                                                              
               On June 10, 2003, S. Partridge (Ms. Partridge) in                      
          respondent’s Laguna Niguel office sent petitioners a letter                 
          rejecting their OIC.  Ms. Partridge determined that petitioners             
          could pay in full the amount due based on financial information             
          submitted by them.                                                          
               To demonstrate that they were obtaining funds to pay their             
          tax liabilities, petitioners faxed a letter to Ms. Partridge on             
          June 16, 2003, informing her of the name and phone number of                






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