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Due Process Hearing (CDP hearing request). Respondent
temporarily lost the CDP hearing request.
On January 17, 2001, petitioner submitted a Form 656, Offer
in Compromise (OIC). Petitioner offered $1,300 in satisfaction
of the balance due for the tax years in question.2 Petitioner’s
wife did not sign the initial OIC. Respondent rejected the OIC
because petitioner failed to respond to a letter requesting
additional documentation. Petitioner did not execute a new OIC
that included both his and his wife’s signatures. Respondent
closed the OIC file on May 15, 2002.
In April 2001, a portion of petitioner’s overpayment for tax
year 2000 was applied to the underpayment for the 1995 tax year.
The liability was paid in full, and on May 18, 2001, the Federal
tax lien for 1995 was released. In August 2001, the remainder of
petitioner’s overpayment for tax year 2000 was applied to the
underpayment for the 1996 tax year. Petitioner does not dispute
the propriety of the offsets to the years in issue.
2 Petitioner’s tax liability for the years in question as
of Dec. 7, 2000:
Form Tax Year Balance Due
1040 1995 $ 433.68
1040 1996 1,623.18
1040 1997 3,728.66
1040 1998 3,954.03
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Last modified: May 25, 2011