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Hearing from respondent.4 On December 16, 2003, petitioners
filed a Form 12153, Request for a Collection Due Process Hearing,
with respect to their unpaid employment and income tax
liabilities for the years 1997 through 2001. On their Form
12153, petitioners requested additional time to enable the U.S.
Trustee to complete the final accounting regarding the bankruptcy
estate and to make final distribution in the bankruptcy case.
Petitioners intend to apply any distribution they receive to
their outstanding tax liabilities.
On or about May 10, 2004, petitioners sent a completed Form
656, Offer in Compromise, to respondent, offering to compromise
specified Federal tax liabilities for $9,024.25. The offer-in-
compromise covered petitioners’ income tax liabilities for 1997,
1998, and 1999 and Mr. Salazar’s employment tax liabilities for
the quarters ending December 31, 1998, through September 30,
1999, and March 31, 2000, through June 30, 2001.5
By letter dated May 14, 2004, respondent scheduled
petitioners’ Appeals Office hearing for June 3, 2004. According
4The record does not indicate for which of petitioners’ tax
liabilities the notice of intent to levy was sent.
5Petitioners contend that they offered to compromise Mr.
Salazar’s unpaid employment tax liabilities for all quarters
ending Dec. 31, 1998, through June 30, 2001. However,
petitioners did not include the quarter ended Dec. 31, 1999, on
the Form 656, Offer in Compromise, they submitted.
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Last modified: May 25, 2011