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On March 13, 2003, petitioner submitted a Form 656, Offer in
Compromise (first offer-in-compromise), with completed Form 433-
A, Collection Information Statement for Wage Earners and Self-
Employed Individuals, offering $600 to compromise his outstanding
tax liabilities for 1990 through 2002.
On March 31, 2003, petitioner filed Form 1040, U.S.
Individual Income Tax Return, for 1999, reporting a tax liability
of $3,059 and payments of $2,752 and $1,292, which represented
tax withheld from 1999 and an overpayment credit from 1998,
respectively. Respondent disallowed the $1,292 overpayment
credit pursuant to section 6511.2
On April 28, 2003, the first offer-in-compromise was
returned because petitioner failed to file a Form 1040 for 1997.
On May 19, 2003, respondent assessed tax liabilities along
with penalties and interest for 1999.
On June 25, 2003, petitioner submitted a second Form 656
with a completed Form 433-A (second offer-in-compromise),
offering $200 to compromise his tax liabilities for 1980 through
2002.
2 The Internal Revenue Service determined the return for
1998 was not filed within 2 years from the time the tax was paid.
Petitioner’s credit from withheld taxes and excess FICA for 1998
was paid on April 15, 1999, and his 1998 Federal income tax
return was filed on May 5, 2003.
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