- 4 -
The record shows no further activity with respect to the
hearing until April 8, 2002, when a second Appeals officer
assigned to conduct the hearing sent a letter requesting that
petitioners review and update their previously submitted Form
433-A and provide additional documents related to their financial
condition. Petitioners submitted the requested information on
April 16, 2002. On their revised Form 433-A, petitioners
indicated they had net equity in their assets of approximately
$67,000 (up from $31,000), and monthly gross income of $7,715 per
month (up from $7,423). Petitioners' monthly expenses remained
unchanged.
By letter dated April 19, 2002, the Appeals officer advised
petitioners that their proposed installment agreement of $1,500
per month was not acceptable because it would not result in
payment of all amounts due within the applicable periods of
limitation on collection. The letter informed petitioners that
an offer-in-compromise might serve as an alternative to the
proposed levy and explained that such an approach would require
petitioners to make a payment equal to the net realizable equity
in their assets, which might require borrowing against those
assets.
On April 22, 2002, petitioners submitted a Form 656, Offer
in Compromise, in which they offered to make a one-time payment
of $67,000 to compromise their aggregate unpaid tax liabilities
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Last modified: May 25, 2011