Michael D. Cornwell and Hilary J. Iker - Page 4
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By law, you are entitled to only one CDP Hearing
under Internal Revenue Code Section 6330 for the unpaid
taxes listed in our Notice of Intent to Levy. This
letter preserves your right to a future CDP hearing
should that become necessary. You don’t need to do
anything further regarding this request. * * *
* * * * * * *
The law entitles you to a CDP Hearing, but the hearing
would take place after the levy or seizure.
The IRS later advised petitioners that the July 15, 2004, letter
rescinding the notice of levy was issued in error.
On May 6, 2005, petitioners and respondent’s Settlement
Officer, Patrick S. Lin (Lin), had a face-to-face meeting to
discuss petitioners’ hearing requests. During the meeting,
petitioners expressed their intent to submit an OIC to settle
their respective tax liabilities for 1994 through 2002.
After the face-to-face meeting, on July 27, 2005,
petitioners filed two separate OICs. The first offered to
compromise petitioner’s individual 1994 through 1996 tax
liabilities for $4,000. The second offered to compromise
petitioners’ joint 1997 through 2002 tax liabilities for $16,000.
Subsequently, petitioners filed amended OICs and increased the
amounts of the offers to: (1) $6,250 for petitioner’s separate
tax liabilities for 1989, 1993, 1994, 1995, and 1996 and
(2) $18,500 for petitioners’ 1997 through 2002 joint tax
liabilities (for a total offer of $24,750).
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Last modified: November 10, 2007