- 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. PetitionersPage: 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