- 2 - Pursuant to section 6330(d), petitioners seek our review of respondent’s determination. The issue for decision is whether respondent’s determination was an abuse of discretion. FINDINGS OF FACT Some of the facts have been deemed stipulated pursuant to Rule 91(f). The deemed stipulations, with accompanying exhibits, are incorporated herein by this reference. Petitioners, John F. Joseph and Carolyn J. Joseph,2 husband and wife, resided in Silver Spring, Maryland, when they filed their petition in this case. John F. Joseph (petitioner) is 69 years of age and has a master’s degree. He is a chemical engineer employed by the U.S. Department of Energy at a grade of GS-15. Petitioners began to experience financial difficulties when their son was diagnosed with a terminal illness. Petitioners’ son died in December 2000. Petitioners filed joint income tax returns for 1998 through 2001 but did not pay the balances due shown on the returns. In November 2000, petitioners entered into an installment agreement with respondent with respect to their 1998 and 1999 income tax liabilities. Petitioners agreed that during the term of the 2Carolyn J. Joseph did not appear at trial. The Court sua sponte will dismiss the case for lack of prosecution with respect to her and enter a decision for respondent with respect to her consistent with the decision entered with respect to John F. Joseph.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011