J. Jean Moore - Page 4

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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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