-2-
was appropriate to sustain collection action with respect to
petitioners’ unpaid income taxes for 1985-89 and 1991-2001 (the
years in issue).2 Thereafter petitioners timely filed a petition
in which they requested our review of respondent’s determination.
The issue for decision is whether respondent’s determination to
reject petitioners’ offer-in-compromise (OIC) and proceed with
collection was an abuse of discretion. We hold that it was not.
Background
Some of the facts have been stipulated and are so found.
Petitioners are married and resided in Edison, New Jersey, at the
time the petition was filed.
Respondent issued a Final Notice of Intent to Levy and
Notice of Your Right to a Hearing to petitioners on September 5,
2002. Petitioners timely requested a collection due process
hearing on October 1, 2002. Petitioners’ outstanding tax
liability is $463,496 plus statutory additions. Petitioners did
not challenge the assessments or the underlying tax liabilities.
A settlement officer (SO) from respondent’s Appeals Office
(Appeals) spoke on the telephone with petitioners’ representative
on February 4, 2003. The SO told petitioners’ representative
that collection alternatives such as an OIC or an installment
2 In the petition, petitioners also disputed the collection
action for taxable year 1990. No notice of determination was
issued to petitioners for that year. By separate order, the
Court dismissed this case as it relates to taxable year 1990.
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