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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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Last modified: March 27, 2008