- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008