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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.
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Last modified: May 25, 2011