- 4 - offered no explanation of why any losses that were incurred in 1994, 1995, and 1996 would not have been taken into account when he belatedly filed, in 1997, his return for 1993. Petitioner has failed to show that the assessed liability for 1993 is erroneous in any respect. Although he claims inability to pay the liability, he has neither offered any collection alternatives nor complied with requirements for an offer in compromise. See sec. 301.7122-1, Proced. & Admin. Regs. On the record in this case, the notice of determination that was sent to petitioner must be sustained. Decision will be entered for respondent.Page: Previous 1 2 3 4
Last modified: May 25, 2011