- 3 - taxable years. The OIC provided that petitioners would pay $32,000 to satisfy these liabilities, with $27,000 to be initially deposited upon respondent’s acceptance of the OIC, and $5,000 to be paid 6 months after respondent’s notice of acceptance. As part of the OIC, petitioners were to “comply with all provisions of the Internal Revenue Code relating to the filing [of] returns and paying [of] required taxes for five (5) years from the date IRS accepts the offer.” Petitioners signed the OIC on January 30, 1997. Respondent accepted petitioners’ OIC by return letter dated March 28, 1997. In his acceptance letter, respondent provided that “the conditions of the offer require [petitioners] to file and pay all required taxes for five years from the date shown in the upper right corner of this letter.” To avoid default on the OIC, petitioners were required to timely file and pay their taxes through March 28, 2002. Over the next 5 years, petitioners either did not timely file, and/or did not timely pay, and/or failed to report all of their income on their Federal tax returns. 1. Taxable Year 1997 Petitioners failed to report all of their income on their 1997 Federal income tax return. Respondent issued a notice of deficiency for taxable year 1997, which petitioners subsequently defaulted. As a result of the default, respondent assessed anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011