Gary W. McDonough - Page 5

                                        - 5 -                                         
          were assessed against petitioner for 1989 and 1991 because of the           
               On August 23, 2002, respondent mailed petitioner a Letter L-           
          1058, Final Notice of Intent to Levy and Notice of Your Right to            
          a Hearing.  The notice informed petitioner that respondent                  
          proposed to levy on his property to collect Federal income taxes            
          owed for 1989 and 1991.  The notice advised petitioner he was               
          entitled to a hearing with respondent’s Appeals Office to review            
          the propriety of the proposed levy.  On August 29, 2002,                    
          petitioner submitted a Form 12153, Request for a Collection Due             
          Process Hearing.  Petitioner indicated he would pursue an offer-            
          in-compromise based on effective tax administration and would               
          provide financial information upon request.                                 
               On March 11, 2003, Appeals received petitioner’s original              
          Form 656, Offer in Compromise, with a completed Form 433-A,                 
          Collection Information Statement for Wage Earners and Self-                 
          Employed Individuals, offering to pay $102,000 to compromise his            
          outstanding tax liability.  Petitioner offered to compromise his            
          outstanding 1985-95 tax liabilities on the grounds of doubt as to           

               4 TBS 1989-1, one of the partnerships in which petitioner              
          invested, was involved in a consolidated case decided by this               
          Court in Durham Farms #1, J.V. v. Commissioner, T.C. Memo. 2000-            
          159, affd. 59 Fed. Appx. 952 (9th Cir. 2003).  As a result of               
          that case, computational adjustments were made, and, on May 13,             
          2002, additional income tax and interest were assessed against              
          petitioner for 1989 and 1991.                                               

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