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petitioner a notice of tax lien filing with regard to the tax
lien that respondent had filed.
On October 24, 2003, petitioner timely requested a section
6320 collection due process (CDP) hearing with respondent’s
Appeals Office for the purpose of securing the release of
respondent’s filed tax lien against petitioner.
On January 1, 2004, petitioner organized a corporation and
transferred her eldercare business to the new corporation.
Ownership of the new corporation was placed 51 percent in
the name of petitioner and 49 percent in the name of petitioner’s
son and daughter-in-law. At some point, petitioner transferred
some of the real property she owned to her daughter.
On March 11, 2004, during the CDP hearing, petitioner
submitted to respondent an offer-in-compromise (OIC). In her
OIC, petitioner offered to make a payment of $258,000 in full
settlement and compromise of her cumulative total then accrued
and outstanding approximate $1.8 million in Federal income taxes,
additions to tax, and interest for 1992 through 1995 and for 1997
through 2002.
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Last modified: May 25, 2011