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obligations throughout the pendency of their cases before
Mr. Skidmore from early 2003 to mid-2004. The notice of
determination for 2000 was issued on November 25, 2003, and that
for 2001 and 2002 was issued on July 13, 2004. Estimated
payments, intended to ensure that current taxes are paid, are a
significant component of the Federal tax system, and Mr. Skidmore
was entitled to rely on their absence in reaching his
conclusions. In fact, petitioners’ circumstances illustrate one
of the reasons for requiring current compliance before granting
collection alternatives such as an offer-in-compromise or an
installment agreement; namely, the risk of pyramiding tax
liability. See Orum v. Commissioner, 412 F.3d 819, 821 (7th Cir.
2005), affg. 123 T.C. 1 (2004).
As to alleged mitigating circumstances during the years in
issue, the Court understands that petitioners had little control
over medical exigencies or an industry slowdown. Petitioners
claim that these circumstances establish that financial
inability, rather than lack of desire, was responsible for their
dilatory filings and payments. Again, however, current
compliance is most germane. In addition, as Mr. Skidmore noted
repeatedly, petitioners’ assertions of financial hardship are
difficult to square with the substantial cashflow through their
accounts. Mr. Skidmore concluded that petitioners’ broad
assertions of business need and use did not satisfactorily
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