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Respondent issued petitioner a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(notice of determination) for unpaid Federal income tax and
related liabilities for 1996 and 1997.2 The notice of
determination asserts that the unpaid balance is $4,249.07.
The issue for decision is whether respondent abused his
discretion by rejecting petitioner’s offer in compromise (OIC).
Background
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Cheverly, Maryland, at the time the
petition was filed.
Petitioner filed a 1996 Federal income tax return on June
17, 1997, and timely filed a 1997 Federal income tax return on or
before April 15, 1998. The 1996 and 1997 returns each reflected
tax due. There was no remittance with either of the returns.
Respondent assessed the taxes due for 1996 and 1997.
Respondent issued petitioner a notice of intent to levy for
the 1993 through 1997 taxable years. Petitioner submitted a
timely Form 12153, Request for a Collection Due Process Hearing.
Petitioner also submitted an OIC. The Appeals officer rejected
petitioner’s OIC, noting that petitioner’s offered amount of $100
for the liabilities outstanding for the tax years 1993 through
2 Respondent, in the notice of determination, conceded the
outstanding tax liabilities for 1993, 1994, and 1995.
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