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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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