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all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
At the time the petition was filed, petitioners resided in
Las Vegas, Nevada.
For 1990, 1991, 1992, and 1993, petitioners filed with
respondent their joint Federal income tax returns. For these
years petitioners still owe respondent approximately $750,000 in
cumulative total Federal income taxes, including accrued
interest.
In November of 2003, petitioners sold their home and
purchased for $589,000 a new home in an expensive neighborhood of
Las Vegas, Nevada, paying $122,000 as a cash downpayment. None
of the proceeds from the 2003 sale of petitioners’ prior home was
used by petitioners to make a payment on petitioners’ outstanding
Federal income taxes for 1990, 1991, 1992, and 1993.
On March 8, 2004, in an effort to collect petitioners’
unpaid Federal income taxes, respondent mailed to petitioners a
notice of intent to levy on petitioners’ property.
On March 15, 2004, petitioners filed a request for a hearing
with respondent’s Appeals Office challenging respondent’s
proposed levy and seeking approval of an offer-in-compromise, in
which petitioners offered to make a total payment of $77,000 with
regard to their Federal income taxes for 1990 through 1993.
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Last modified: May 25, 2011