Donald A. and Virginia M. Singer - Page 3

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         as to collectibility.3  Petitioners offered to pay $10,000, with             
         $3,000 as an initial payment and 21 monthly payments of $333                 
         thereafter.  As of June 18, 2003, petitioners owed approximately             
         $33,006.31 in taxes, penalties, and interest for the years in                
         issue.  Both the offer in compromise and the hearing request were            
         assigned to Settlement Officer Marilyn Q. Alls.                              
              On July 7, 2003, a hearing was conducted by telephone                   
         between Settlement Officer Alls and petitioner Donald A. Singer.             
         Settlement Officer Alls had no prior involvement with the taxes              
         that were the subject of the proceeding.  In the hearing,                    
         Settlement Officer Alls verified that all legal and procedural               
         requirements had been met.  Amounts due had been properly                    
         assessed, notice and demand had been made, the taxes were still              
         outstanding, and a levy source was identified and available.                 
         Settlement Officer Alls verified that the proposed action                    
         balanced the need for efficient collection of taxes with the                 
         concern that any collection action be no more intrusive than                 
         necessary.                                                                   
              In her review, Settlement Officer Alls determined that                  
         petitioners had the ability to pay the liability in full over the            


               3Petitioners did not check any of the boxes in sec. 6 of               
          Form 656 to indicate the offer was based on doubt as to                     
          collectibility or otherwise.  However, the statement attached to            
          petitioners’ Form 656 claims they are unable to pay and mentions            
          no exceptional circumstances, such as permanent disability, that            
          would merit compromise based on effective tax administration.               





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