William H. and Jo Anne Lindley - Page 6

                                        - 6 -                                         
          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               







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011