- 3 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011