- 7 -
Petitioners attached several exhibits to the May 14, 2004
letters.
The Form 656 indicated that petitioners were seeking an
offer-in-compromise based on either doubt as to collectibility
with special circumstances or effective tax administration.
Petitioners offered to pay $99,851 to compromise their
outstanding tax liabilities for 1981 through 1996.7 At the time
of the section 6330 hearing, $187,041 had been assessed against
petitioners with respect to their 1981 through 1996 tax years.
On the Form 433-A, petitioners listed the following assets:
Asset Current Balance/Value Loan Balance
Checking account $5,226 n/a
Savings accounts 322 n/a
Mutual fund 12,167 -0-
Cash value of life 1,191 -0-
insurance policy
1997 Ford Expedition 7,650 -0-
1978 Ford F-250 De minimis -0-
1964 Ford Falcon De minimis -0-
House 220,200 $82,009
Personal effects 4,000 -0-
Total 250,756 82,009
7 The details of petitioners’ 1989-1996 taxable years are
not in the record.
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