- 4 - counsel.5 Cochran and petitioners’ counsel discussed two issues. The first issue concerned petitioners’ intent to offer to compromise their 1982 through 1996 Federal income tax liability to promote effective tax administration. Petitioners contended that Appeals should accept their offer as a matter of economic hardship, equity, and public policy. Petitioners stated that it took a long time to resolve the Hoyt partnership cases and noted that Hoyt had been convicted on the criminal charges. The second issue concerned an interest abatement case under section 6404(e) that petitioners had pending in this Court. That case related to the same years at issue here. Petitioners claimed that the proposed levy should be rejected because that case was pending. On June 7, 2005, petitioners tendered to Cochran on Form 656, Offer in Compromise, a written offer to pay $100,000 to compromise their estimated approximately $275,000 liability. The offer was limited to a claim of effective tax administration because petitioners had sufficient assets to pay the liability in full. Petitioners supplemented their offer with a completed Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals, four letters totaling approximately 75 pages, and volumes of documents. The Form 433-A reported that 5 Petitioners were 69 and 72 years old at the time of the hearing.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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