Homer W. and Nancy L. Winans - Page 13

                                       - 13 -                                         
          during the administrative process and could have but did not                
          raise it.                                                                   
               The settlement officer assigned to petitioners’ case offered           
          petitioners several opportunities to propose collection                     
          alternatives or to provide other pertinent information.  However,           
          petitioners responded with nothing but frivolous arguments.                 
          Petitioners did not make an offer in compromise, offer to pay               
          their delinquent taxes under an installment plan, or tell the               
          settlement officer that petitioner had requested assistance on              
          hardship grounds from the Taxpayer Advocate Service.  Petitioners           
          did not give the Appeals Office the opportunity to conduct an               
          independent review of their financial circumstances.  Other than            
          submitting a copy of the Countrywide complaint, petitioners                 
          offered the Court no support for their hardship claim.                      
               Petitioners are in their late 50s and have both been                   
          gainfully employed in recent years.  There is no indication (a)             
          how petitioners used the funds that should have been withheld               
          from petitioner’s wages, (b) that petitioners have dependents or            
          unusual financial demands, or (c) that the proposed collection              
          actions would cause petitioners to be unable to pay their                   
          reasonable basic living expenses.  See sec. 301.6343-1, Proced. &           
          Admin. Regs.                                                                

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011