Douglas W. and Gail Caple - Page 3




                                        - 2 -                                         
               This matter arises from a petition for judicial review filed           
          in response to a Notice of Determination Concerning Collection              
          Action(s) Under Section 6320 and/or 6330 issued for unpaid                  
          Federal income tax for taxable years 1993 and 1994.1                        
               The issues for decision are:  (1) Whether petitioners may              
          contest the liabilities respondent assessed for the taxable years           
          1993 and 1994, (2) whether respondent properly abated interest              
          and adjusted accuracy-related penalties assessed against                    
          petitioners for 1993 and 1994 in accordance with an agreement               
          between the parties, and (3) whether respondent’s Appeals officer           
          abused her discretion in rejecting petitioner’s offer-in-                   
          compromise.                                                                 
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      
               Petitioners resided in Appleton, Wisconsin, on the date the            
          petition was filed.  Until 1994, petitioner Douglas W. Caple (Mr.           
          Caple) worked as a night-shift first-aid responder at Ocean Angle           
          Steel, an industrial plant.  After leaving this position sometime           


               1 The outstanding Federal tax owed for taxable year 1993 has           
          been paid in full as a result of respondent’s applying                      
          petitioners’ overpayment refunds from subsequent years to the               
          amount owed for taxable year 1993.  Respondent also applied a               
          portion of petitioners’ overpayment refunds to the amount owed              
          for taxable year 1994.  As of Aug. 21, 2006, the outstanding                
          liability owed for 1994 was $14,670.74.                                     





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