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MEMORANDUM OPINION
VASQUEZ, Judge: The controversy before us arises out of
petitioners’ opposition to respondent’s motion to remand the case
to the Appeals Office.
Background
On July 30, 2002, respondent issued a Notice of Federal Tax
Lien filing to petitioners. The lien covered unpaid income tax
for the taxable years 1989, 1993, 1995, 1996, and 1999. On
September 9, 2002, petitioners filed a Form 12153, Request for a
Collection Due Process Hearing, in which they indicated that they
did not believe they owed all of the assessed tax liabilities and
they wanted to file an Offer in Compromise. A Notice of
Determination was sent to petitioners by the Appeals Office which
sustained the lien. On August 11, 2003, petitioners filed a
petition to the Tax Court.
On April 30, 2004, respondent moved that the case be
remanded to the Appeals Office to consider “Petitioners’ Offer in
Compromise and allegations that * * * [petitioners] do not owe a
portion of the assessed tax liabilities.” Respondent
concurrently moved for continuance of trial, removal of the case
from the scheduled trial session, and restoration of the case to
the general trial docket.
On May 5, 2004, the Court granted respondent’s motion for
continuance and motion for remand to the Appeals Office.
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Last modified: May 25, 2011