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filing (NFTLF) with respect to 1999 and 2001 on April 28, 2004.
As petitioner’s request for a hearing was not timely filed as to
the NFTLF for 1999 and 2001, he received only an equivalent
hearing on those issues. Petitioner has accumulated tax
liabilities of more than $24,000 for 1999, 2000, 2001 and 2003.
The record does not reflect any activity by respondent relative
to 2003.
On the same date that petitioner filed his Form 12153,
respondent received from petitioner a letter stating that he had
submitted a Form 656, Offer-in-Compromise (OIC), on account of
doubt as to collectibility, for 1999, 2000, and 2001. The OIC,
received on January 12, 2004, was returned. Petitioner
resubmitted his OIC along with a Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals, both dated May 29, 2004. Petitioner later
supplemented his OIC with additional information attached to an
“Amended/Revised” OIC signed and dated July 6, 2004. The
amended/revised OIC included 2003 as well as 1999, 2000, and
2001. In November of 2004, petitioner sent to respondent a
letter enclosing an “updated” Form 433-A with attachments.
All of petitioner’s OICs requested a “Short-Term Deferred
Payment Offer”, which must be paid more than 90 days, but within
24 months, from acceptance. Petitioner offered to pay $2,500 on
his outstanding tax liabilities in all three versions of his OIC.
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Last modified: May 25, 2011