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Petitioners argued that the proposed levies were inappropriate,
that they were entitled to relief based on equity, hardship, or
public policy considerations, and that Mrs. Lindley was entitled
to innocent spouse relief. Under “collection alternatives
considered”, petitioners checked only an installment agreement.
Petitioners’ case was assigned to Settlement Officer Thomas
Owens (Mr. Owens) in respondent’s Birmingham, Alabama, Appeals
office. Mr. Owens initially scheduled a telephone section 6330
hearing for October 28, 2004. However, after a conversation with
petitioners’ representative, Jennifer Gellner (Ms. Gellner), Mr.
Owens agreed to delay the hearing to allow petitioners to submit
an offer-in-compromise and any materials they wished to be
considered.
On or around November 4, 2004, petitioners submitted to Mr.
Owens a Form 656, Offer in Compromise, a Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals, and three letters setting out in detail petitioners’
position regarding the offer-in-compromise. Petitioners attached
several exhibits to the letters and provided a diskette
containing 42 additional exhibits.
The Form 656 indicated that petitioners were seeking an
offer-in-compromise based on doubt as to liability, doubt as to
collectibility, or effective tax administration. Petitioners
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