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Forms 433-A and 656 have been prepared and filed with
the IRS as an Offer in Compromise. The only real
estate owned by the taxpayers is their personal
residence * * *. Such residence constitutes exempt
property, and therefore, the IRS’ attempted lien is
unenforceable.
Petitioners’ Request for a Collection Due Process Hearing was
signed by their then attorney.
On February 12, 2003, a telephone conference was held
between respondent’s Appeals Officer Eugene H. DeBoer (DeBoer)
and petitioners’ attorney. On February 13, 2003, DeBoer wrote to
petitioners’ attorney a letter summarizing their discussion and
stating the following:
In regards to your question about changes to the
alternative minimum tax laws. At this time there is no
pending legislation that would retroactively change how
the AMT was computed for 2000. Accordingly, the tax as
reported appears to be correct.
Neither petitioners nor their attorney responded to the
February 13, 2003, letter from DeBoer. Instead, petitioners’
attorney contacted their Senator and the Taxpayer Advocate
Service.
On August 12, 2003, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was sent to
petitioners. The attachment to the notice explained the
determination as follows:
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Last modified: May 25, 2011