William J. and Lois J. DiCindio - Page 4




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          March 1, 2005, stating that they had decided not to submit an OIC           
          because they would have no way of paying the debt.  Trial was               
          held on September 19, 2005, in New York, New York.                          
               Following trial, the Court ordered petitioners to provide              
          counsel for respondent a complete Form 656, Offer in Compromise,            
          and an updated Form 433-A, Collection Information Statement for             
          Wage Earners and Self-Employed Individuals.  Counsel for                    
          respondent received petitioners’ OIC on November 15, 2005, and              
          sent it to an offer specialist (OS) for consideration.  In the              
          following months, the OS requested that petitioners provide                 
          additional information by various deadlines.  Petitioners did not           
          meet any of these deadlines.                                                
               In April 2006, petitioners requested that the Court keep the           
          pending OIC open for consideration until August 15, 2006, so that           
          petitioner could file his 2005 income tax return.  The Court                
          denied petitioners’ request.  Thereafter, respondent returned the           
          pending OIC to petitioners and closed their file because                    
          petitioners had failed to provide additional information                    
          necessary to determine the acceptability of their offer and they            
          failed to verify their compliance with the estimated income tax             
          requirements for 2005 and 2006.                                             
                                     Discussion                                       
               Petitioners contend that respondent’s refusal to consider              
          their offer-in-compromise submitted on November 15, 2005, for the           







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